With crystal clarity, the U.S. Government has signaled its intentions regarding enforcement of the Foreign Corrupt Practices Act (FCPA): far greater resources devoted to FCPA investigations, and far harsher penalties for FCPA violations.
Last year, the Department of Justice (DOJ) brought a record 26 enforcement actions under the FCPA. The Securities and Exchange Commission (SEC) had its second busiest year for FCPA enforcement, with 14 actions, and has created a specialized unit devoted solely to FCPA investigations. Corporate fines have reached record levels — $1.6 billion in global penalties in the case of Siemens A.G., and $579 million in penalties against Halliburton/KBR.
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