Glencore Resolution: Part IV – The Resolution
Tom Fox examines the settlement of the Department of Justice's FCPA enforcement action against Glencore plc, commenting that “there was some serious misconduct going on here, for multiple years, in multiple countries with multiple schemes.” Nonetheless, Glencore received “not-insignificant” discounts of about $100 million (out of a roughly $1.1 billion overall penalty), under the DOJ's FCPA Enforcement Policy and U.S.
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