We’re only eight months into 2014 and it has already been a big year for enforcement activity under the U.S. Foreign Corrupt Practices Act. In the first half of 2014 alone, the U.S. Department of Justice and the U.S. Securities and Exchange Commission initiated 15 actions against companies alleged to have violated the international corruption law. The agencies also have nailed down some hefty settlements this year: like the $384 million that Alcoa Inc. and one of its subsidiaries agreed to hand over in January.
With big-ticket settlements such as this on the books, the $2 million that firearms manufacturer Smith & Wesson Holding Corp. recently agreed to pay to settle FCPA charges might sound like a small-caliber hit. But a closer look at the case offers some lessons about FCPA enforcement and how companies should respond when faced with bribery and corruption accusations.
