This further means (and I can’t believe I actually have to write this) that a Top Ten List of FCPA Enforcement Actions should only include enforcement action in which the corporate defendant was actually charged with FCPA (as opposed to other) offenses.
When one performs accurate and consistently applied math, the recent Telia FCPA enforcement action is not the largest, third largest, or fourth largest FCPA enforcement action of all-time, but rather the fifth largest. (See here for the list of Top Ten FCPA Enforcement Actions).
‘Enforcement 40’ for 2020
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