Piling On? Examining the Reality of Multi-Jurisdictional FCPA Resolutions

With the rise in anti-corruption prosecutions, settlements and penalties outside of the United States, often in conjunction with related U.S.-based enforcement activity, many are concerned that enforcement agencies are “double-dipping” or “piling on” – forcing companies to pay duplicative fines to U.S. and foreign authorities. In this guest article, Ropes & Gray attorneys Ryan Rohlfsen, Stephanie Busalacchi and Kassandra Jordan examine the trends in FCPA enforcement over the last three years to see how often the DOJ has cooperated and shared penalties with foreign jurisdictions. They also analyze how both the DOJ’s prior conduct and its newly announced policy will impact companies. See “How Significant Is the DOJ’s New Directive on Coordination?” (May 16, 2018).

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