It was a “two for Tuesday” yesterday as the DOJ announced a Foreign Corrupt Practices Act (and related) enforcement action against Olympus Latin America Inc. and related entities and the SEC announced an FCPA enforcement action against Qualcomm.

This post highlights the Qualcomm action and a future post will highlight the Olympus action.

FCPA Professor has been following Qualcomm’s FCPA scrutiny since it was announced in January 2012 (see here).

…

As the Second Circuit recognized in a recent high-profile SEC matter, “trials are primarily about truth” whereas SEC settlements are “primarily about pragmatism.” (see here for the prior post). As Stanford Law Professor and former SEC Commissioner Joseph Grundfest has noted: “it can be imprudent for regulated entities to engage in protracted litigation with their regulators.”