Deciphering Mixed Signals: The Impact of ABB Ltd.’s (Third) FCPA Resolution

With its December 2022 settlement, ABB Ltd. has become the first and thus far only corporate entity to have  resolved  three separate FCPA enforcement actions with U.S. authorities. Despite Deputy Attorney General Lisa Monaco’s recent statements, there was no monitor imposed pursuant to ABB Ltd.’s most recent criminal FCPA resolution. In this guest article, Robert Johnston and Trip Connors, attorneys at Lowenstein Sandler, discuss whether corporate monitors are in fact back “en vogue” as the DOJ has suggested, and whether, after this first of its kind multilateral settlement with South African authorities, we should expect to see additional foreign regulators actively cooperating with U.S. authorities in cross-border criminal matters. See “ABB Settles With Multiple Authorities for Its Third FCPA Strike” (Dec. 7, 2022).

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