[Updated December 31, 2009] In 2009, prosecutors kept their promise to pursue individuals who violated the Foreign Corrupt Practices Act. Thirty-three were named in enforcement actions brought by the DOJ or SEC — the most for any year since enactment of the law in 1977. This year’s list includes those indicted, arrested, convicted, sentenced, or civilly charged. Last year, we counted 24 individuals involved in similar enforcement actions, plus David Kay and Douglas Murphy, whose petition for certiorari to the U.S. Supreme Court was denied.
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