Over the past decade, and particularly in the last five years, law enforcement actions against international corruption have become commonplace. What is noteworthy as we enter 2012 is precisely how routine the activity in this area has become. The U.S. Department of Justice (DOJ) suffered a couple of embarrassing setbacks in its enforcement efforts, although these are unlikely to have any longterm impact on the program. Efforts to amend and scale back the Foreign Corrupt Practices Act (FCPA or the Act) have gained support both in Congress and some sectors of the business community, but even if adopted these will do little to alter the fundamental features of the enforcement landscape. The fact is that anti corruption law enforcement achieved a certain level of stability, and we can expect, for 2012 and beyond, essentially more of the same—a regular flow of cases against both companies and individuals, primarily but not exclusively by U.S. authorities, many with penalties in the tens or hundreds of millions of dollars and, at least for an unlucky few, prison terms of multiple years....
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