Significant Sentences May Signal Continuing Commitment to Individual FCPA Enforcement

Several recent sentencings of individuals for FCPA violations or related matters may not have shed much light on corporate FCPA enforcement in the Trump administration, but could point towards a continued commitment to individual prosecutions. The 2017 sentencings of Mahmoud Thiam, Dmitrij Harder and Samuel Mebiame for crimes associated with corruption “certainly represent significant white collar prison terms designed to punish the offenders and deter similar conduct,” observed Richard Hartunian, a partner at Manatt and the former United States Attorney for the Northern District of New York. The Anti-Corruption Report analyzes these developments in individual FCPA enforcement. See “DOJ Reiterates Commitment to FCPA Enforcement but Resources May Become an Issue” (Jul. 19, 2017) and “SEC and DOJ Address Corporate Concerns About Future FCPA Enforcement” (Jun. 7, 2017).

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