Those bemoaning the lack of Foreign Corrupt Practices Act (FCPA) enforcement activity can cease. With the Dun & Bradstreet Inc. (D&B) declination in April and May’s enforcement action involving Panasonic Avionics Corporation (PAC) and its parent Panasonic Corporation (Panasonic), U.S. regulators at the Department of Justice (DOJ) and Securities and Exchange Commission (SEC) have roared back with not only significant enforcement actions, but more importantly for the compliance practitioner, important information about how the DOJ will consider enforcement actions under the new FCPA Corporate Enforcement Policy, announced last November.
Tom Fox explores Panasonic’s failings and lessons the compliance practitioner can learn from this company’s misdeeds.
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Thomas Fox has practiced law in Houston for 25 years. He is now assisting companies with FCPA compliance, risk management and international transactions.
