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Over the past few years, U.S. government enforcement agencies have substantially increased the number of investigations—and resulting enforcement actions—of companies and individuals in Latin America over alleged violations of the Foreign Corrupt Practices Act (FCPA). Of particular importance—the number of FCPA prosecutions with a Latin American component is also increasing, indicating that government regulators are taking a hard look at alleged violations of the FCPA in Latin America. Specifically, in 2010 and 2011, the Department of Justice (DOJ) disclosed approximately 44 FCPA and related enforcement actions, with 14 of them, or 32 percent, having a Latin American component.

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