Regrouping And Refocusing: 2013 FCPA Year-In-Review And Enforcement Trends For 2014


Following a relatively flat enforcement landscape and some bumps in the 2013 prosecutorial road, the Department of Justice (‘‘DOJ’’) and the Securities and Exchange Commission (‘‘SEC’’) appear poised to spring back into action on Foreign Corrupt Practices Act (‘‘FCPA’’) and related anti-corruption enforcement. Other nations have also ramped up activity in this arena by fortifying their laws and enforcement outlooks, including by bringing ‘‘carbon copy’’ actions. Below, we take a look at the major FCPA and anti-corruption developments of 2013, as well as what may be in store for 2014.

- U.S. Enforcement Numbers Continue to Trail the Records Set in 2010 — But the DOJ and SEC Remain Committed to Aggressive Enforcement.

Calendar year 2010 saw the U.S. DOJ initiate a record-breaking 48 enforcement actions and the SEC bringing 26. But prognostications to the contrary notwithstanding, the intervening years have not witnessed a redoubling of this trend. More specifically, in 2013 the DOJ filed only 16 FCPA and related enforcement actions (and announced 2 non-prosecution agreements, and 6 enforcements actions that were filed in 2012 and 2011), while the SEC for its part brought 8 actions.

Originally Published in Bloomberg BNA Securities Regulation & Law Report - January 20, 2014.

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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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