Foreign Corrupt Practices Act 2015 Update

Despite a decline in enforcement actions by the Securities Exchange Commission ("SEC") and the Department of Justice ("DOJ"), the first half of 2015 has continued to highlight the relevance and ever-evolving effects of the Foreign Corrupt Practices Act ("FCPA"). Notable in the first half of 2015 was the SEC's willingness to look beyond the foreign official bribery provision of the FCPA, as it instituted actions for inadequate internal controls and violations of the FCPA's books and records provisions against companies including Polycom, BHP Billiton, and Goodyear Tire & Rubber Company ("Goodyear"). In May, the DOJ demonstrated its willingness to go beyond the FCPA's provisions to tackle foreign corruption. The Fédération Internationale de Football Association ("FIFA") conspiracy resulted in the DOJ indictment of at least 14 individuals so far for racketeering, wire fraud, and money laundering. As the controversy continues to unravel, it demonstrates the concerted