FCPA Corporate Settlements of 2014: Details, Trends and Compliance Takeaways

FCPA enforcement remained strong in 2014 with the DOJ and the SEC resolving cases with 10 companies for a total of $1.6 billion, the highest enforcement take since 2010.  However, the majority of the funds, approximately 72%, came from two major enforcement actions ($772 million from Alstom and $384 million from Alcoa).  The cases reveal that the government continues to pursue companies in a variety of industries from a mix of nations.  The settling companies range from a technology company, to a firearm manufacturer, to a cosmetics manufacturer and hail from France, America and Japan.  We summarize the salient points of each settlement and distill lessons from these enforcement actions.  See “FCPA Corporate Settlements of 2013: Details, Trends and Compliance Takeaways” (Dec. 18, 2013).

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