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Harry Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Richard L. Cassin Editor at Large

Elizabeth K. Spahn Editor Emeritus 

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor


FCPA Blog Daily News

« Canada’s new DPA regime brings internal controls to the forefront | Main | Court rules Hoskins must face FCPA trial »
Wednesday
Aug212019

What are the best months to open and close FCPA investigations?

Is there a favorite season or special time of the year that's best for closing FCPA investigations or disclosing new ones?

I looked at a 32-month period, starting from January 1, 2017. From then till now, 55 FCPA-related investigations have been closed. The most common month for closing them has been May, with nine. September is the second most popular, with eight.

June and July are tied for third with seven FCPA investigation closures each. 

The least popular month? January has only had a single investigation closure since the start of 2017. 

It appears, then, that summer is the preferred season for closing FCPA investigations. Companys' fiscal calendars likely have more to do with this than the weather.  

However, the most common month to first disclose an FCPA investigation is February, followed by April and March, respectively. 

Already this month, one investigation has closed and two companies have disclosed new investigations, including Avianca

In July this year, five companies disclosed new investigations. 

I researched this post using FCPA Tracker's Screener tool. 

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Harry Cassin is the publisher and editor of the FCPA Blog.