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When the government comes knocking: Trends in FCPA enforcement actions

Sabrina Skeldon (skeldonsabrina@gmail.com) is a former Assistant US Attorney for the Western District of Louisiana and a former senior counsel to the Office of the Inspector General, and is based in Dallas, Texas, USA.

The Foreign Corrupt Practices Act (FCPA) bribery investigation has concluded, and the Department of Justice (DOJ) has determined that no bribery violation has occurred; however, the Securities and Exchange Commission (SEC) subsequently notifies your client that a civil enforcement investigation has been opened into the same conduct for alleged violations of the FCPA internal accounting provisions. What can you expect to face, and how do you navigate the FCPA internal accounting controls enforcement action? What can you learn from recent FCPA enforcement actions?

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