The Dun & Bradstreet Enforcement Action — A Microcosm of the Many Problems with FCPA Enforcement

13 Bloomberg Law White Collar Crime Report 470 (2018)

4 Pages Posted: 29 May 2018

See all articles by Mike Koehler

Mike Koehler

Southern Illinois University School of Law

Date Written: May 25, 2018

Abstract

The April 2018 Foreign Corrupt Practices Act enforcement action against The Dun & Bradstreet Corp. (D&B) was in many respects unremarkable. The $9.2 million settlement amount was nowhere near the top FCPA settlements and the enforcement action did not usher in any new enforcement theories. Because of this, most FCPA observers likely just recorded the enforcement statistics and moved on. This would be a mistake however because, as highlighted in this article, the unremarkable D&B enforcement serves as a microcosm of the many problems with FCPA enforcement ranging from the length of scrutiny, to various legal and remedy issues, to even absurd commentary that often follows FCPA enforcement.

Keywords: FCPA, Foreign Corrupt Practices Act

Suggested Citation

Koehler, Mike, The Dun & Bradstreet Enforcement Action — A Microcosm of the Many Problems with FCPA Enforcement (May 25, 2018). 13 Bloomberg Law White Collar Crime Report 470 (2018). Available at SSRN: https://ssrn.com/abstract=3186326

Mike Koehler (Contact Author)

Southern Illinois University School of Law ( email )

1150 Douglas Drive
Carbondale, IL 62901-6804
United States

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