Compliance Lessons From Recent Nine-Figure FCPA Settlements

One notable FCPA enforcement trend on the SEC front, specifically, is the regulator appears to be bringing more standalone charges for violations of the books and records and internal accounting controls provisions under the FCPA, where violations of the anti-bribery provisions are noticeably absent. Microsoft, Walmart, Fresenius, and Juniper Networks are just a few recent examples.

“That shows that companies need to be paying particular attention to their internal controls,” says Matthew Nielsen, a partner at law firm Bracewell. Also, whereas historically FCPA cases have been concentrated in a handful of highly regulated industries—such as oil and gas, life sciences, healthcare, and financial services—it may be that cases start to expand into a broader range of industries.

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