An enforcement action by the U.S. Securities and Exchange Commission or Department of Justice can burden even a prepared organization and result in serious financial consequences. With the number of Foreign Corrupt Practices Act actions proliferating across industry types and organization sizes, and fines growing larger each year, it is increasingly important to be prepared to alleviate the impact to the business.
Recent decisions by the SEC and DOJ appear to indicate willingness to mitigate or reduce fines if companies investigate quickly and thoroughly, and transparently share information with the investigating body. This type of cooperative approach may significantly impact the financial fallout of such an investigation, but must be approached carefully.
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