2015 Begins With A Drop In FCPA Enforcement Activity

Law360, New York (April 20, 2015, 1:36 PM EDT) -- The pace of enforcement under the U.S. Foreign Corrupt Practices Act has slowed considerably in 2015, with just three resolved enforcement actions during the year's first quarter — all brought by the U.S. Securities and Exchange Commission — which represents the lowest level of enforcement to begin a year since 2006. This downturn comes after a spike in enforcement during the fourth quarter of 2014 to levels not seen in four years.

When factoring in the apparent drop in newly disclosed FCPA investigations (see the "Known Investigations Initiated" chart below) and the uptick this quarter in the number of disclosed declinations...

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