Foreign Corrupt Practices Act Alert
December 23, 2008
Siemens Settlement & the FCPA
December 22, 2008
This Update reviews the widely covered agreement of Siemens AG to plead guilty to violating the United States Foreign Corrupt Practices Act (“FCPA”) and German anti-corruption laws and pay a staggering $1.6 billion in penalties. Noting that “the stakes are now even higher than before,” the Alert should serve as a stark reminder that FCPA enforcement actions will escalate as will the degree and sophistication of intra-agency and international cooperation in tracking down and prosecuting corrupt practices.
December 18, 2008
This Alert looks at the extraordinary conclusion to the one of the largest investigations into corporate bribery in history. The total of the fines in the
The Alert also notes that this FCPA enforcement action reflects several recognizable FCPA trends, including the trend of larger monetary penalties, the DOJ’s commitment to prosecuting individuals, and the importance of a company’s appropriate and effective response to red flags that might signal illicit payments.