"Declination May Not Be the End"

6/16/15: Declinations are usually perceived as the end of an enforcement action but recent actions by US enforcement agencies show otherwise. According to a post by Richard Cassin on the FCPA Blog, the US Securities and Exchange Commission recently notified NET1 UEPS Technologies that it declined to recommend...an enforcement action following its investigation into the company’s possible FCPA violations. So far, so good, but the US DOJ hasn’t given any indication that it was following the same course, which leaves NET1 less than completely relieved. That’s only one curious element of the US investigation.