Credit for self-disclosure and cooperation in corporate criminal FCPA cases - Financier Worldwide

    23 February 2011

    Since 2005, the US Department of Justice (DOJ) has dramatically increased its criminal enforcement activity under the Foreign Corrupt Practices Act (FCPA).  More FCPA cases have been brought in the last five years than were brought in the previous 30-year history of the statute. This growth in enforcement activity has continued notwithstanding the change of US presidential administrations as well as the change in the relevant leadership of the DOJ office responsible for investigating and prosecuting FCPA cases. With respect to corporations, the 10 largest corporate FCPA matters have all been resolved in the last two years, and have included a total of over $2bn in criminal fines. Moreover, eight of these 10 largest corporate cases have been against non-US companies.

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    Reprinted with permission from Financier Worldwide Magazine.