Comments on: Inside FCPA Enforcement Statistics http://www.fcpaprofessor.com/inside-fcpa-enforcement-statistics A Forum Devoted to the Foreign Corrupt Practices Act Tue, 11 Jun 2013 22:49:22 +0000 hourly 1 http://wordpress.org/?v=3.4.2 By: Mike Koehler http://www.fcpaprofessor.com/inside-fcpa-enforcement-statistics#comment-18562 Mike Koehler Wed, 18 Jul 2012 23:08:18 +0000 http://www.fcpaprofessor.com/?p=5239#comment-18562 That may be true, but that link would be very indirect whereas the three examples cited are directly responsible for approximately 35% of FCPA corporate enforcement actions 2007-2011. That may be true, but that link would be very indirect whereas the three examples cited are directly responsible for approximately 35% of FCPA corporate enforcement actions 2007-2011.

]]> By: Howard http://www.fcpaprofessor.com/inside-fcpa-enforcement-statistics#comment-18560 Howard Wed, 18 Jul 2012 13:55:21 +0000 http://www.fcpaprofessor.com/?p=5239#comment-18560 I also wonder how many enforcement actions, or investigations, can be traced indirectly to Siemens. After Siemens, the notoriety of the FCPA went up by an order of magnitude. General Counsels and Chief Compliance Officers took notice, and remediation began. Creating programs and looking into pre-existing ones led to discovery of lots of issues, which led to self-disclosures. What do you think? I also wonder how many enforcement actions, or investigations, can be traced indirectly to Siemens.

After Siemens, the notoriety of the FCPA went up by an order of magnitude. General Counsels and Chief Compliance Officers took notice, and remediation began.

Creating programs and looking into pre-existing ones led to discovery of lots of issues, which led to self-disclosures.

What do you think?

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