Just between April and June 2018 there were five FCPA enforcement actions. These enforcement actions end up with big fines against corporations for a total of $985 million, two people in jail and one guilty plea: Credit Suisse Group Ag $47 million, Société General S.A $585 million, Legg Mason Inc $64 million, Panasonic Corporation and Panasonic Aviation Corporation $280 million and Dun & Bradstreet Corporation $9 million. The two people who were sentenced to served time in prison are: Ng Lap Seng to 48 months in prison, Lawrence W. Parker Jr to 35 months in prison, and one pleaded guilty, Julia Vivi Wang.
All these five FCPA enforcement actions lead to some kind of agreement with the US authorities by the corporations. For be able to reach these agreements is necessary that the corporation conducted an internal investigation and to have adequate compliance programs. Also other forth corporations started internal investigations related to possible FCPA enforcement, Transocean Ltd, Archock Inc, Dun & Bradstreet and United Technologies Corporation.
These alleged violations of the FCPA took place in different countries: Kong, Libya, Several countries of Middle East and Asia (in the Panasonic case), China, Aruba, Brazil, beside others. this makes it clear to us how important are the compliance programs worldwide.