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ARTICLE · 19 FEBRUARY 2016

Anti-Corruption

When compared to prior years, 2015 was relatively quiet for Foreign Corrupt Practices Act (FCPA) enforcement actions in the US.

GlobalCriminal Law

Focus on the US

An active FCPA docket anticipated

When compared to prior years, 2015 was relatively quiet for Foreign Corrupt Practices Act (FCPA) enforcement actions in the US. Although the total number of enforcement actions was slightly higher than the previous year, there was an absence of the very large monetary settlements that garnered enormous attention in the recent past. This record, combined with continued criticism that their enforcement actions in the past failed to hold individuals accountable for violations of federal law, including the FCPA, may be the reasons for two significant changes in the government's approach to enforcement. This raises the question as to whether the coming year will be much less quiet than the previous year.

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