FCPA + Anti-Corruption Developments: 2012 End Of Summer Round-Up

While the temperatures rose this summer, the number of Foreign Corrupt Practices Act ("FCPA") enforcement actions seems to have cooled off for the first time in the last five years. However, the leveling-off in the number of cases is not an indication that US regulators are losing interest in FCPA enforcement. To the contrary, all indications are that the fight against corruption—in the United States and elsewhere—will continue to heat up in the months and years to come.

Here are some highlights:

SPOTLIGHT ON INDIVIDUALS

In February 2010, Assistant Attorney General Lanny A. Breuer announced that the prosecution of individuals would be a "cornerstone" of the regulators' FCPA "enforcement policy."¹ Mr. Breuer has been true to his word: there has been a spike in actions against individuals. But, the government's cases against individuals have met with mixed success, with some record-breaking prison sentences, on the one hand, and stinging judicial rebukes, on the