All told, as an SEC Commissioner, Peirce has voted on 42 corporate FCPA enforcement actions. In 10 of the actions (approximately 25%) Peirce voted not to approve. In 25 of the actions (approximately 60%), Peirce objected to certain aspects of the enforcement action. In other words, Peirce has objected (in whole or in part) to approximately 85% of corporate FCPA enforcement actions during her tenure as an SEC Commissioner.
‘Enforcement 40’ for 2020
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