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Antibribery enforcement may have gotten off to a slow start in 2013, but by now, the Department of Justice’s 12 enforcement actions this year have already surpassed its 2012 enforcement total, according to Gibson Dunn’s “2013 Mid-Year FCPA Update.”

“This year we’re likely to end back up in the prior levels of 20 to 25” Foreign Corrupt Practices Act (FCPA) cases, says Gibson Dunn senior associate John Chesley, referring to the DOJ’s FCPA enforcement levels in 2008, 2009, and 2011.

One explanation for a seeming lull in enforcement activity is that, as the Justice Department becomes a more active investigator in international antibribery cases, it is also filing many cases under seal. “There may be some lag time between when cases are filed and when they actually become public,” says Chesley, who is a co-author of the firm’s report. For its part, the Securities and Exchange Commission has so far brought four FCPA enforcement actions this year.

Here are some key findings from the latest report:

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