Emerging FCPA Enforcement Strategy

Sheppard Mullin Richter & Hampton LLP
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Law360, New York (February 16, 2010) -- On Jan. 18, 2010, FBI agents arrested 22 executives and employees of 16 companies as a result of "the largest action ever undertaken by the Justice Department against individuals" for violations of the Foreign Corrupt Practices Act, a federal anticorruption statute that generally outlaws the practice of bribing foreign officials in order to obtain or retain business.

The indictments resulted from a complex sting operation described by Assistant Attorney General Lanny A. Breuer as "the first large-scale use of undercover law enforcement techniques to uncover FCPA violations."

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