19 January 2016
Of the twelve corporate actions resolved in 2015, almost half of which had a significant Asia Pacific connection, ten were subject to civil resolution by the US Securities and Exchange Commission (SEC) only, with just two being subject to criminal resolution by the US Department of Justice (DOJ). While 2015 was notable for this increase in the number of resolutions based on books-and-records and internal controls violations, the drop in DOJ corporate prosecutions should be seen as temporary given the DOJ's recent staffing increases.
Our top ten list for 2015 considers all five of the corporate prosecutions in 2015 that featured a significant Asia Pacific connection, and also looks at a number of other FCPA-related actions and activities pertinent to companies operating in the Asia Pacific region. In each case, we highlight key points for clients to consider when implementing and managing anti-corruption policies and programmes in the region going forward.