Tracking Towards a Banner Year for FCPA and FCA Enforcement
Robert N. Wilkey, Esq., Staff Writer for Life Science Compliance Update
There are some strong indicators to suggest that 2016 is on track to be a real banner year regarding Foreign Corrupt Practices Act (“FCPA”) enforcement and qui tam actions. One of the most notable indicators is that FCPA enforcement for 2016 is on track to exceed actions for 2015, with to data, actions involving a total of 13 corporate and three individuals, including most significant the VimpelCom case. Additionally, newly unsealed qui tam cases show the FCPA focus on health care and hi-tech companies and the enforcement actions involving other countries, in particular, China is growing. This year is also an introduction to the DOJ’s pilot program.