Pub K
DOJ Declines to Prosecute But Boston Consulting Group Disgorges $14.4 Million in FCPA Matter

Despite evidence of an FCPA violation, DOJ declined to prosecute due to several factors, including Boston Consulting Group’s timely & voluntary disclosure of the misconduct and remediation, firing staff involved, and strengthening its compliance program and internal controls. The company also agreed to disgorge ill-gotten gains.
