Jenner & Block

FCPA Mid-Year 2015 Update: Regulators Focus On Cooperation; Show Breadth Of Enforcement Tools

The first half of 2015 saw a number of important developments in Foreign Corrupt Practices Act (FCPA) investigations and enforcement.  But, as described in our mid-year update, the most significant events took place in matters where no FCPA charges were brought at all.

The DOJ Emphasized Disclosure and Cooperation in Rare Public Declination Announcement.  In June, the DOJ announced that it would not prosecute PetroTiger, Ltd., an oilfield services company that was under investigation for alleged FCPA violations.  

Regulators Promise Transparency Regarding Cooperation and Disclosure Expectations.  In addition to showing the potential benefits of cooperation in the PetroTiger case, senior DOJ and SEC officials also spoke of their agencies’ credit for cooperation.  

Meanwhile, the DOJ’s indictments in the “World Cup of Fraud” FIFA case highlighted how the DOJ can use its broad enforcement tools to investigate and prosecute suspected international commercial corruption that is outside the scope of the FCPA.  

For more information about this publication or Jenner & Block's FCPA Practice, contact Jessie K. Liu  or Nicholas R. Barnaby