So far, 2019 has seen less activity in terms of enforcement
actions under the Foreign Corrupt Practices Act
("FCPA"), compared to 2018. In 2019, the
United States Department of Justice
("DOJ") took a total of 22 enforcement
actions, 1 and the Securities and
Exchange Commission2
("SEC") took a total of 11 enforcement
actions.3
DOJ Declination Decisions
The DOJ had been investigating violations of the FCPA by
Quad/Graphics Inc. ("Quad"), due to the
fact that it had uncovered evidence relating to Quad's Peruvian
subsidiary paying or promising to pay over USD 1 million to
third-party intermediaries, which were partly used to pay bribes to
Peruvian government officials for securing printing contracts with
government agencies, minimizing penalty payments related to delayed
execution of contracts with government agencies and owed tax
payments. In September 2019, the DOJ announced that it would
decline to proceed with the prosecution of Quad, on the grounds
that Quad
