The Foreign Corrupt Practices Act—A Look Back at 2012 and 2013

Over the last two years, enforcement of the Foreign Corrupt Practices Act (“FCPA”) has remained a priority of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”). That emphasis is likely to continue through 2014 and beyond. On November 19, 2013, at an annual FCPA conference held outside of Washington D.C., the deputy chief of DOJ’s FCPA unit, Charles Duross, said that he anticipates DOJ will bring “very significant, top-10-quality type cases” next year and that the government has increased its investment in the FCPA enforcement program. At the same conference, Kara Brockmeyer, chief of the SEC’s FCPA unit, told the audience, “You’re going to see us working with…counterparts that we haven’t necessarily worked with before.”

In short, the FCPA enforcement boom that started around 2005 was not a short-lived change in enforcement priorities, but rather a substantial shift in the way DOJ views foreign corruption. That shift has led to more prosecutions and greater resources being devoted to the Department’s anticorruption efforts. Companies should expect the federal government and, increasingly, foreign authorities to continue to devote significant resources to investigating and punishing FCPA violations. In this alert, we discuss a number of notable developments in FCPA enforcement over the past two years. We have also provided brief summaries of the FCPA resolutions entered by corporations in 2012 and 2013 and a chart summarizing key information from each resolution.

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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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