Embraer Global Settlement Presages a New Paradigm in International Enforcement and Next-Level Compliance
"Embraer, the world’s largest manufacturer of mid-size jets, recently settled allegations that it had violated the FCPA when engaging in transactions spanning the globe. The settlement is a striking example of how the SEC and DOJ are working with foreign governments all over the world to investigate and prosecute corruption in a coordinated manner. At a recent event at the George Washington University Law School (GWU), Assistant Attorney General Leslie R. Caldwell explained that the increase in international collaboration is not only enhancing the DOJ’s FCPA enforcement efforts, “but it is also resulting in growing numbers of anti-corruption enforcement actions by other countries,” and cited the Embraer settlement as an example of how that coordination can lead to holding individual wrongdoers accountable overseas. This sentiment was repeated by top officials at the ACI FCPA Conference."
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