Checklist of Collateral Consequences From FCPA Enforcement Actions

Many companies and executives are well familiar with the significant direct consequences that arise from the resolution of FCPA enforcement actions. These include criminal convictions and fines for the company, disgorgement of profits, civil penalties, and prejudgment interest, as well as the potential for SEC/DOJ mandated corporate compliance monitors. Less familiar and often overlooked are the many and often substantial collateral consequences of entering into FCPA resolutions. The Foley & Lardner Anti-Bribery/FCPA team has for some time been compiling a list of these collateral consequences and this article represents their initial list and some examples from FCPA enforcement actions. We invite our readers to share additional consequences, examples, or other suggested modifications to the list by email to with the subject “Collateral Consequences Checklist.” 

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