couThe pace of international law enforcement cooperation in the anti-corruption setting has quickened since 2009. Even so, there is a widespread perception among in-house counsel that Western regulators including the U.S. Department of Justice and Securities and Exchange Commission cannot easily pursue anti-corruption matters that require significant assistance from their foreign counterparts, particularly those in the developing world. This assumption is dangerous, as it can lead to poorly conceived anti-corruption risk analysis and potentially disastrous decision-making in the event of an investigation.
We found, after a review of every high-profile Foreign Corrupt Practices Act enforcement action brought by the DOJ or SEC since 2009, that in fact developing countries often offer extensive anti-corruption support and that foreign partners can instigate and turbo charge U.S. investigations. Even Switzerland has become a robust anti-corruption partner. To reach these conclusions, we analyzed publicly available materials, including press releases, legal commentary, news articles and information provided during FCPA seminars.
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