During the recently completed second quarter of 2016, the Department of Justice (“DOJ”) resolved three matters, the same number as during the first quarter, and the Securities and Exchange Commission (“SEC”) resolved four matters, down from eight in the first quarter. Financial penalties and disgorgement ordered in these actions exceeded $24 million. In resolving its four actions, the DOJ appeared to be following the principles outlined in the Department of Justice Fraud Section Foreign Corrupt Practices Act (“FCPA”) Enforcement Plan and Guidance (“DOJ Pilot Program”). In addition, during the second quarter, the IRS issued a ruling noting that disgorgement paid to the SEC in an FCPA enforcement action is not tax deductible and the 11th Circuit Court of Appeals held that SEC disgorgement actions are subject to a five year statute of limitations.
 See, DOJ Launches FCPA Self-Reporting Program, Ellen Zimiles and Jay Perlman, Guidehouse April 2016