2012 year-end FCPA update

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2012 year-end FCPA update - .PDF file.

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”.

Click on the link above to download this Gibson Dunn & Crutcher briefing.