Analysis

FCPA Policy Benefits Open To Repeat Bribery Offenders

Law360 (July 9, 2019, 9:15 PM EDT) -- French oil conglomerate TechnipFMC was recently called out by the U.S. Department of Justice for one of its predecessor companies being a Foreign Corrupt Practices Act "recidivist," but the settlement shows that being a repeat offender doesn't block a company from getting cooperation and remediation credit.

The recent settlement resolved the company's criminal liability over bribery in Brazil and Iraq by the company's predecessors, Technip SA and FMC Technologies. The settlement highlights that the DOJ views being a "recidivist" as one factor among many in deciding how severe a punishment should be for a second offense.

Kara Brockmeyer, a partner at...

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