SEC Releases First Deferred Prosecution Agreement in Tenaris FCPA Case

June 06, 2011
The recent deferred prosecution agreement reached between the Securities and Exchange Commission and Tenaris, S.A. is the first such agreement since the SEC launched its new “Cooperation Initiative” in January 2010. As it involves a violation of the Foreign Corrupt Practices Act, the agreement sheds valuable light on how the SEC will use prosecution-style cooperation agreements in investigations of FCPA violations. In this update, we analyze the elements of the agreement, what the agreement tells us about the future of SEC enforcement and what it means for companies that do business abroad.