Litigation partners Mark Mendelsohn and Elizabeth Hanft and counsel Benjamin Klein published an expert analysis in Law360 discussing U.S. regulators’ recent agreement not to prosecute Liberty Mutual Insurance Co. following nearly eight months without corporate Foreign Corrupt Practices Act resolutions and prosecutions. In “Lessons From Liberty Mutual FCPA Declination,” published on September 2, the authors break down the agreement to demonstrate that Liberty Mutual satisfied the five requirements necessary for declination, and compare the decision to five resolutions regulators have entered into with insurance and reinsurance companies since 2012 to consider broader enforcement trends. As the first FCPA resolution by the current administration and the first one issued following updates to FCPA guidelines, this case exemplifies how the declination evaluation process may operate going forward.
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