Law360 (January 17, 2020, 3:20 PM EST) -- Enforcement of the Foreign Corrupt Practices Act is at an all-time high, and 2019 marks the fourth consecutive year where results broke the records that had been set in the previous year. Notably, this heightened level of enforcement is a departure from FCPA enforcement historically.
During the first 30 years of enforcement, from the time the FCPA was passed in 1977 through 2007, the FCPA was largely ignored by the U.S. Department of Justice and the U.S. Securities and Exchange Commission, with enforcement actions against approximately 70 companies (averaging just over two cases each year) resulting in fines and disgorgement of...
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