“In case you haven’t been keeping score, the FCPA has quickly become one of prosecutors’ favorite tools. The Justice Department brought 24 enforcement actions in 2010, up from five in 2004. Penalties have increased geometrically, with criminal fines in fiscal 2009 and 2010 combined totaling nearly $2 billion, up from about $11 million in 2004.”
How High Is Up?
Founder of the FCPA Blog and Editor at Large. He has been named multiple times as one of the 100 Most Influential People In Business Ethics by Ethisphere Magazine and is a Trust Across America Top Thought Leader. He’s a member of the DC, Virginia, and Florida bars. His At Large column is a regular feature of the FCPA Blog.