After a particularly slow second quarter, FCPA enforcement activity picked up between July and September of 2024, with the DOJ initiating one new FCPA-related enforcement action, unsealing two previously filed actions, and issuing one declination letter, according to a tally from Stanford University's FCPA Clearinghouse.
Deere & Co. [12749]
Boston Consulting Group [12712]
AAR Corporation (Aviation MRO Services) [12604]
Smartmatic (Voting Machines) [12615]
"Enforcement activity through Q3 of this year remained well below even the last three years of lower than average enforcement" the report notes.
The number of individual defendants the SEC and DOJ have charged with FCPA-related violations has declined considerably since 2019, with the SEC initiating its last FCPA-related action against an individual in 2020.
According to information disclosed in SEC filings and charging and settlement documents, neither the DOJ nor the SEC concluded a publicly-disclosed investigation in the third quarter of 2024, and now new investigations were initiated.
December 2023's Foreign Extortion Prevention Act (FEPA). criminalized demand-side bribery by foreign officials, and was meant as a complement to the existing supply-side enforcement under the FCPA. July Technical corrections via the Foreign Extortion Prevention Technical Corrections Act Accorfing to the Stanford Clearinghouse, "it does not appear the DOJ has charged any official under either FEPA or FEPTCA.."
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