2012 FCPA Enforcement Trends And Developments

Although the number of U.S. Securities and Exchange Commission (SEC) and Department of Justice (DOJ) Foreign Corrupt Practices Act (FCPA) enforcement actions brought in the first eight months of 2012 has declined considerably from the total number brought in 2011¹, several revealing developments have occurred thus far this year. Highlights for 2012, which are described more fully below, include: the importance of corporate cooperation, clarification regarding successor liability and the impact of the Dodd-Frank whistleblower rules on FCPA enforcement. In addition, we look forward to the much anticipated release of the DOJ's FCPA guidance and legislative reform initiatives.

2012 Highlights