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How Companies Can Respond to the Boom in FCPA Enforcement Fueled by International Cooperation

By Ephraim “Fry” Wernick and Pete Thomas

In this article, V&E partner Ephraim “Fry” Wernick and V&E associate Pete Thomas explain what is behind the dramatic rise in coordinated prosecutions between the United States and foreign authorities and what this means for multinational companies with business operations around the world.

“Over the past several years, DOJ and SEC, which have historically brought the vast majority of the world’s foreign bribery enforcement actions, have made an intentional and concerted effort to cultivate international relationships and share substantial portions of large fines and disgorgement amounts with their foreign counterparts. That investment has paid dividends. Through their efforts, DOJ and the SEC have incentivized other countries to refer new cases to them, resulting in mutually beneficial relationships based on enhanced cooperation and collaboration in international corruption cases.”

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This information is provided by Vinson & Elkins LLP for educational and informational purposes only and is not intended, nor should it be construed, as legal advice.