The Modern Reality Of The FCPA

Law360, New York (February 11, 2009, 12:00 AM EST) -- The number and severity of U.S. Department of Justice and Securities and Exchange Commission enforcement actions pursuant to the Foreign Corrupt Practices Act (“FCPA”) have steadily increased.

In 2008 alone, the DOJ and SEC brought 11 enforcement actions against organizations and 26 against individuals. There are nearly 50 pending FCPA investigations, some involving up to 12 companies from a single industry.

In recent years, companies increasingly have been held accountable not only for the actions of their employees, but also for the actions of their business...
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