The U.S. Department of Justice, the Securities and Exchange Commission and the Office of Foreign Asset Control have increasingly focused on international investigations. In the last few years, the DOJ and SEC have exacted hefty penalties for violations of the Foreign Corrupt Practices Act (FCPA), antitrust regulations, export controls and other laws governing international conduct. For example, in a recent case, Weatherford International, an oil and natural gas company, paid $253 million in criminal and civil penalties for allegedly violating the FCPA and export laws by authorizing bribes, travel and entertainment for foreign officials in the Middle East and Africa.
The first steps in responding to a government investigation are crucial; seemingly small decisions at the initial stages of an investigation can have huge repercussions down the road.
