In a telephone conference call sponsored by the ABA, Lorin Reisner, Deputy Director of Enforcement at the SEC, disclosed that the SEC is relying on data analytics and industry-specific risk analysis to initiate FCPA investigations. Reisner’s disclosure is extremely significant because he specifically explained that investigations initiated as a result of voluntary disclosures by companies constitute a smaller percentage of the SEC’s investigations…. Instead of relying on voluntary disclosures, the SEC is using proactive techniques to identify risk areas where industries may be engaged in bribery.
‘Enforcement 40’ for 2020
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