Importance of Cooperation Credit in FCPA Settlements
GovCon & Trade
JANUARY 12, 2024
I recently provided comments for an article in the Anti-Corruption Report examining recent Department of Justice (DOJ) settlements under the Foreign Corrupt Practices Act (FCPA). In two of the settlements, U.K.-based reinsurance brokers settled charges for more than $47 million in penalties and disgorgement; a third entity paid no fines and was only subject to disgorgement.
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