The Man From FCPA tends to see FCPA enforcement actions as both teaching vehicles for compliance professionals and communication tools of government enforcement agencies such as the SEC and the Justice Department. He found the recently released Nu Skin FCPA enforcement action both provided both. The matter was relatively small enforcement, in terms of the monetary sanctions, with a civil money penalty in the amount of $300,000, coupled with a disgorgement profits in the amount of $431,088, plus prejudgment interest of $34,600. However, the matter has several interesting aspects for the Chief Compliance Officer or compliance practitioner to consider.
