2009 continued the escalation of civil and criminal enforcement
actions undertaken by the Department of Justice ("DOJ")
and the Securities and Exchange Commission ("SEC"). Just
looking at cases under the Foreign Corrupt Practices Act
("FCPA"), the DOJ is currently pursuing more than 100
investigations. All indications are that the government's
increased focus on foreign bribery, among other activities, will
continue into the next decade. Government officials have made
statements in recent months reinforcing the government's
commitment to continued aggressive enforcement of the
anti-corruption laws.
Because the stakes are high, when a company learns that it is
the focus of any government investigation, or facts are discovered
that require the company to start its own internal investigation,
the general counsel and/or chief compliance officer must be ready
to respond quickly and navigate a series of complex issues that
will arise very early in the investigation. Based
