Enforcement activity under the Foreign Corrupt Practices Act continues to increase. Indeed, federal prosecutors are now utilizing other statutes to sweep into U.S. jurisdiction corrupt business payments that may fall outside the jurisdiction granted by the FCPA and aggressively pursuing export, financial and other types of violations that come to their attention during FCPA investigations. In addition, the focus of this enforcement effort has expanded beyond companies to include individual businesspeople and corporate agents.
Moreover, the number of government entities looking into corrupt business practices abroad has expanded. In addition to the Justice Department’s Criminal Division and the U.S. Securities and Exchange Commission’s Enforcement Division in Washington, several U.S. attorney’s and SEC field offices around the country are now in the FCPA enforcement business.
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