Recent Trends and Patterns in FCPA Enforcement/FCPA Digest
21 Feb 2008
Danforth Newcomb,
Philip Urofsky
This publication provides current and comprehensive information on U.S. foreign bribery proceedings including criminal prosecutions, DOJ foreign bribery civil actions, SEC actions, DOJ opinion releases, ongoing FCPA investigations, pre-FCPA prosecutions and parallel litigation related to the FCPA.
This edition highlights the increased aggressiveness of FCPA enforcement by the DOJ and SEC in all stages, from investigation to prosecution. Certain trends have emerged in concert with this heightened FCPA activity, including: an increase in the prosecution of individuals alongside companies, the use of more creative methods, such as deferred/non-prosecution agreements, to resolve FCPA criminal cases, an expansion in the use of post-proceeding compliance monitors, a rise in parallel international investigations under the anti-corruption laws of other nations and parallel litigation related to the FCPA, and a spike in the self-reporting of FCPA problems discovered as part of merger or acquisition activity.
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Click here to view Recent Trends and Patterns in FCPA Enforcement report only.
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