The SEC Noble Prosecution: Takeaways from the O’Rourke, Jackson and Ruehlen Settlements
In the realm of FCPA enforcement, where the vast majority of cases are settled before the filing and litigation of formal charges, it is often hard to compare the outcomes of early and eve-of-trial or post-trial settlements in any meaningful way. The Noble case, however, providesa rare opportunity to engage in such a comparison, not only because it was litigated by the SEC farther than almost any other FCPA case has been, but also because it involved both pre-and post-litigation settlements for individual defendants based on charges arising out of the same series of events.
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