For many years, SEC enforcement officials have talked about the importance of individual FCPA enforcement actions and set forth below are representative quotes from over the years.
The last individual FCPA enforcement action by the SEC occurred on October 14, 2020 (a gap that is approaching two years) – see here.
This nearly two year gap is the most significant gap in individual FCPA enforcement by the SEC in nearly a decade.
Since late October, 2020 there have been seven corporate SEC FCPA enforcement actions and none of them have involved related actions against individuals.
‘Enforcement 40’ for 2020
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