DOJ and SEC Continue to Stress the “Holy Trinity” of Self-Disclosure, Cooperation and Remediation 

Big cases, lengthy investigations and robust enforcement of the FCPA are the hallmarks of 2016, noted commentators at a recent Practicing Law Institute panel on FCPA developments. “This was a very good year for SEC FCPA enforcement,” said Neil Smith, Senior Counsel with the SEC Division of Enforcement. Expanded enforcement can be chalked up to a committed workforce, good relations between the SEC and DOJ and “strong partnerships overseas where we continue to leverage our contacts with foreign regulators, foreign criminal authorities and other folks to bring about enforcement,” he said. According to James Loonam, Deputy Chief of the Business and Securities Fraud Section of the U.S. Attorney’s Office in the Eastern District of New York, DOJ enforcement also remains strong. See “Top FCPA Enforcers Discuss Evolving and Diverging Enforcement Approaches and the Defense Bar Responds” (Dec. 2, 2015).

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