FCPA Compliance: Tone At The Top, Train At The Bottom

Law360, New York (October 19, 2010, 1:52 PM EDT) -- The current international anti-corruption focus of the U.S. Department of Justice, the U.S. Securities and Exchange Commission and other government prosecutors is here to stay, according to all indications. The last two years have seen an unprecedented increase in the number of prosecutions under the Foreign Corrupt Practices Act, and a dramatic increase in the size and scope of the prosecutions.

With the imposition of criminal sanctions into the billions of dollars in 2010 alone, and the United States government’s demonstrated focus on prosecuting individuals as...
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