The Shift In FCPA Enforcement Targeting

Law360, New York (September 28, 2009, 11:32 AM EDT) -- The U.S. Department of Justice and the Securities and Exchange Commission in recent years have significantly expanded their Foreign Corrupt Practices Act enforcement activity.

Enforcement actions during the last several years against large multinational companies have grabbed the headlines with both prosecutions and huge monetary settlements that have awakened corporate compliance officers and in-house counsel with tremors not felt since the immediate post-Enron days, and its progeny — Sarbanes-Oxley, et al.

These enforcement actions, awakening the multinational company, together with the DOJ Sentencing Guidelines that significantly...
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