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ARTICLE · 30 JULY 2012

Recent Setbacks For FCPA Enforcement

De Brauw Blackstone Westbroek
De Brauw Blackstone Westbroek
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De Brauw Blackstone Westbroek

De Brauw Blackstone Westbroek

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The US Foreign Corrupt Practices Act ("FCPA") prohibits US persons and companies from bribing foreign officials to obtain business.

NetherlandsCriminal Law
Patrick Ploeger
Patrick Ploeger
Marnix Somsen
Marnix Somsen
Roan Lamp
Roan Lamp
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The US Foreign Corrupt Practices Act ("FCPA") prohibits US persons and companies from bribing foreign officials to obtain business. Enforcement actions initiated by US regulators under the FCPA have risen sharply in recent years (see also RCE Newsletter January 2012). Research now shows that US regulators faced a number of setbacks in FCPA enforcement actions recently. These setbacks include vacated convictions and irregularities found during the investigation phase.

Research specifies that the number of FCPA enforcement actions initiated by the SEC and DOJ decreased in 2011 (48) compared to 2010 (74). The number of FCPA enforcements in the first half of 2012 totaled 14.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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