Paul Weiss Discusses New Signs of Vigorous FCPA Enforcement

As the end of their fiscal years approached on September 30, the Department of Justice and the Securities and Exchange Commission announced a number of resolutions, underscoring their pronouncements that “vigorous enforcement”[1] of violations of the Foreign Corrupt Practices Act remains a “high priority”[2] for both agencies.  These resolutions, which we summarize in this memorandum, provide more significant detail about the underlying FCPA violations than did previous resolutions, in keeping with the DOJ’s stated “effort to promote both transparency and accountability”[3] through their publication and the SEC’s desire to build a “robust disclosure regime.”[4]  Along similar … Read more