• In 2004, the DOJ collected about $11 million in criminal fines. In 2009 and 2010 combined, the DOJ collected nearly $2 billion in criminal fines.

  • The FBI has trained a special investigative unit for FCPA violations.

  • FCPA enforcement officials currently have more than 150 criminal and 80 civil investigations underway.

  • New FCPA whistleblower provisions increase risks.

  • In 2010, 52 individual businesspeople were indicted, sentenced, or convicted and are awaiting sentencing for FCPA violations.

  • Enforcement officials resolved 6 FCPA enforcement actions in 2002. In 2010, they resolved 71.

  • In 2010 alone, five FCPA settlements exceeded $100 million.

  • The amount of FCPA penalties tripled between 2009 and 2010.

  • Individuals are facing significant FCPA fines and jail time for authorizing improper payments.

  • FCPA actions are increasingly brought against small and medium-sized companies as well as high-profile multinational corporations.


Internal Investigations

Matteson Ellis Law, PLLC conducts independent internal investigations for companies that have identified possible FCPA violations and need assistance determining appropriate corrective action.

Before legal counsel can assess a potential bribery violation by an employee, a company must gather all relevant facts related to the transaction. Internal investigations should be conducted by experienced lawyers, forensic accountants, and investigators. For investigations to be effective, practitioners must understand how to maintain legal privilege, protect attorney work product, comply with local laws, and acknowledge the legal rights of those interviewed. Internal investigations must also be conducted in an efficient and timely manner given the competitive nature of the global marketplace.

Matteson Ellis Law, PLLC has extensive experience conducting complex internal investigations in over 20 countries throughout the Americas, Asia, Europe, and Africa. These countries are considered “high corruption risks” by international monitoring organizations. Our global network of seasoned forensic accountants and investigators allows us to conduct highly effective investigations no matter the geographic location, language requirements, or risk environment.

Yerevan, Armenia