New FCPA Enforcement Actions: Are You Mitigating This Risk?

SAP Concur published an article analyzing two recent FCPA enforcement actions by the U.S. Department of Justice (DOJ). Both cases were resolved through 'declinations with disgorgement,' with companies paying approximately $11.2 million and $4 million respectively. The DOJ stated that lenient treatment was based on timely voluntary self-disclosure and full cooperation. The article also outlines the FCPA Pilot Program framework for voluntary self-disclosure and full cooperation, and recommends companies manage risk through T&E tool configuration, data visibility, and compliance reporting.