Not since November, 2010, when the Justice Department announced its many settlements with Panalpina on Foreign Corrupt Practices Act charges, have we seen such a stunning back-to-back announcement of resolution of long-running and highly public FCPA enforcement actions.
I am, of course, referring to the Avon and Alstom FCPA enforcement actions announced in December. Alstom engaged in multi-country bribery schemes over several years, sometimes in the open and sometimes (seemingly) trying to hide the details of the bribery to the corporate headquarters in France. Avon engaged in a systematic bribery scheme in one country (China) followed by a cover-up at the highest levels of the company when the scheme was uncovered by the company’s internal audit function. Both enforcement actions have several key points worth noting.
