AML・FCPA ：enforcement report for Q3 2020：Herbalife Nutrition
AML・FCPA ：
During the third calendar quarter, there were three corporate FCPA enforcement actions with penalties and disgorgement totaling about $182.7 million.
During Q3 2019：
For comparison, during the third calendar quarter in 2019, there were seven corporate FCPA enforcement actions with penalties and disgorgement totaling about $78.5 million.
During Q3 2018：
there were also seven corporate FCPA enforcement actions, with total penalties and disgorgement of about $1.97 billion, including $1.78 billion for Petrobras.
This quarter’s largest ：Herbalife Nutrition
This quarter’s largest financial penalty was Herbalife Nutrition, which paid the DOJ and SEC $123 million in August to resolve FCPA violations in China.
Two individuals were sentenced during the third quarter, and three were indicted.
Four individuals entered guilty pleas in Q3.
There were three corporate declinations, including
KBR’s Unaoil-related investigation
GSK’s China investigation.
According to FCPA Tracker：
five companies disclosed new FCPA-related investigations during the third quarter,
including consumer health giant Johnson & Johnson.
The FCPA Blog
https://fcpablog.com/2020/10/01/fcpa-enforcement-report-for-q3-2020/
Herbalife Nutrition Ltd. Agrees to Pay Over $122 Million to Resolve FCPA Case | OPA | Department of Justice
https://www.justice.gov/opa/pr/herbalife-nutrition-ltd-agrees-pay-over-122-million-resolve-fcpa-case