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ARTICLE · 23 JANUARY 2012

Anti-Corruption Enforcement Developments: 2011 Year-In-Review And 2012 Preview

WilmerHale
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The year 2011 proved to be another busy year for enforcement of the Foreign Corrupt Practices Act ("FCPA"), as well as anti-corruption efforts globally.

United StatesCriminal Law
Roger Witten
Roger Witten
Jay Holtmeier
Jay Holtmeier
Tim Matthews
Tim Matthews
Saniya O'Brien
Saniya O'Brien
Kimberley Parker
Kimberley Parker
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I. Introduction

The year 2011 proved to be another busy year for enforcement of the Foreign Corrupt Practices Act ("FCPA"). The US Department of Justice ("DOJ" or "Department") and the US Securities and Exchange Commission ("SEC") continued their vigorous enforcement efforts, initiating a total of 23 and 26 cases, respectively.1 A flurry of activity in December doubled the number of cases brought by DOJ and nearly doubled those brought by the SEC. There were 26 cases brought against companies and 23 cases brought against individuals. Both DOJ and the SEC have made the prosecution of individuals for FCPA violations an enforcement priority, and cases brought in 2011 reflect the continued pursuit of that goal. For example, the year ended with DOJ charging eight former executives and intermediaries of Siemens AG and its subsidiaries and the SEC filing charges against six of the same individuals and settled charges against a seventh former executive; civil charges were

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