Foreign Corrupt Practices Act Hits its Stride

As the Foreign Corrupt Practices Act (FCPA) turned 35 years old in 2012, the surge in enforcement activity that was first observed five years ago appears to be leveling off. Nevertheless, numerous events in 2012 signal a statute that is maturing rather than falling into obscurity; increasing ability and enthusiasm by the government to conduct industry-wide investigations; and serious policy debates between industry, executive and legislative interests leading up to the much-anticipated issuance of statutory guidance from the government.

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