Client Alert

Quarterly FCPA Report: Second Quarter 2010

July 08, 2010

William F. Pendergast, Jennifer D. Riddle, Sara A. Murphy, Christina Hardjasa & Russell D. Johnson

The second quarter of 2010 has been relatively quiet, in contrast to the record-breaking number of FCPA enforcement actions initiated in the first quarter of the year. While the U.S. Securities and Exchange Commission (SEC) reported four enforcement actions during the quarter, the U.S. Department of Justice (DOJ) filed only two FCPA cases toward the end of the second quarter.

The lack of new prosecutions, however, is not an indication that the federal government is relaxing its FCPA enforcement efforts. In April 2010, Charles Edward Jumet received the longest sentence ever imposed for a violation of the FCPA. In the last week of June, the DOJ and SEC announced long-awaited settlements with Technip, and in first week of July, the two agencies announced settlements with Snamprogetti and ENI. These settlements were all in relation to the Nigerian Bonny Island bribery scheme that has now netted the U.S. government $1.28 billion in criminal and civil penalties thus far. Additionally, the DOJ and SEC are continuing investigations into a variety of multinational corporations such as Panalpina and HP.

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