Harry Cassin Publisher and Editor

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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. 


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