Off to the Races in 2012: DOJ’s Fast Start in FCPA Enforcement


Talk about seeing the forest from the trees – during the same week that Judge Hughes granted the defense motion for judgment of acquittal in the O’Shea case, the Justice Department announced a $56 million settlement in the Marubeni case, and Biomet disclosed it was planning on an FCPA settlement in the $30 million range. Late last year, two major companies announced they were close to significant criminal settlements in major cases.

The number one trend/prediction for 2012 looks like it is coming to fruition – DOJ is back to collecting major criminal fines from corporations. It looks like the Justice Department is off to a fast start.

There will be more twists and turns in the coming months – expect a wiretap case and expect a huge criminal fine settlement in a high profile case. But DOJ’s criminal fines collections for FCPA violations will continue to ramp up, especially in comparison to 2011.

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