DOJ and the SEC to U.S. Businesses: We Expect Action on Effective Compliance Programs

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Based on my experience as a U.S. Attorney, I see the new joint Department of Justice (“DOJ”) and Securities Exchange Commission (“SEC”) Resource Guide to the Foreign Corrupt Practices Act (“FCPA”) as a game changer that presents important opportunities for clients with an international footprint. The message from Lanny Breuer at DOJ and Rob Khuzami at the SEC should be loud and clear: it is time to examine and improve your compliance plan because the government wants U.S. businesses to lead the charge in defeating foreign corruption by effective internal efforts — and for those who don’t heed the call, there will be consequences.

FCPA enforcement has exploded in the last ten years from just a handful of enforcement actions in 2004 to more than 70 in 2010, during the time I was U.S. Attorney for Oregon. We’re still considering the implications, but here are some quick take-aways that I see, having worked closely with key authors of the Resource Guide on various enforcement efforts when I was in office...

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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