June closed out one of the most interesting half-years in the FCPA realm. In Q1 alone, we’ve had the Cognizant Technology Solutions declination, the Fresenius non-prosecution agreement and the Mobile TeleSystems (MTS) deferred prosecution agreement (DPA). June brought a resolution to Walmart, “the big one,” with an FCPA enforcement action, and just a few weeks ago came the TechniFMC enforcement action with a DPA and guilty plea from the company’s U.S. subsidiary.
Here, Tom Fox discusses the details of the violations and offers lessons for the compliance practitioner.
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