2012 year-end FCPA update
By comparison to the blistering pace set in recent years, FCPA prosecutions were down in 2012 (although still far higher than in any of the first 30 of the statute’s 35-year existence). Does this portend the end of the FCPA Era — left on the cutting room floor of the Sequester? Can US companies relax their vigilance? Not according to Lanny A Breuer, Assistant Attorney General for DOJ’s Criminal Division, who recently commented that “robust FCPA enforcement has become part of the fabric of the Justice Department” and a “reality that companies know they must live with and adjust to” — a reality from which “there is no turning back”.
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On 23 October 2012, the United Arab Emirates enacted its Federal Competition Law (Federal Law No. (4) of 2012), which laid down new rules on anti-competitive agreements, merger control and abuse of dominance.
In retrospect, 2012 likely will be remembered as another year of manifold challenges in the Eurozone and of slow consolidation rather than one of fundamental reform or renaissance.