February 20, 2015
From Gibson Dunn
Within the last decade, Foreign Corrupt Practices Act ("FCPA") enforcement has become a juggernaut of U.S. enforcement agencies. Ten years ago, we published our first report on the state-of-play in FCPA enforcement. Although prosecutions were at the time quite modest--our first update noted only five enforcement actions in 2004--we observed an upward trend in disclosed investigations and advised our readership that enhanced government attention to the then-underutilized statute was likely. From the elevated plateau of 2015, we stand by our prediction.