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Resource Alert: The Sweep Of Enforcement

Hughes Hubbard (a sponsor of the FCPA Blog) continues its tradition of providing an invaluable resource to the compliance community through publication of its FCPA / Anti-Bribery Alert. The latest version for Summer 2012 is now out and available here.

At 400 pages, the new edition is packed with insight into the sweep of enforcement trends, along with detail about every recent enforcement action. That scope makes this version of the FCPA / Anti-Bribery Alert, like earlier releases, an indispensable tool for practitioners, compliance professionals, academics, and researchers.

The team at Hughes Hubbard responsible for the Summer 2012 edition was led by partner Kevin Abikoff, pictured above. He chairs the firm’s anti-corruption and internal investigations practice group.

Here’s part of his introduction:


. . . Enforcement efforts are not limited to companies that have failed to adopt appropriate policies and procedures or have a rogue employee. Rather, we have seen regulatory attention dedicated to companies who had publicly (or privately to regulatory authorities) indicated that they had adopted an effective compliance program only to be found to have either a mere paper program or one that was begun and abandoned. Such instances have been and will be dealt with harshly by authorities who rely on companies to develop and maintain programs, particularly in instances where they have provided assurances in this regard or where regulatory authorities have reduced penalties in reliance on the adoption of an enhanced compliance program.

Finally, there is the persistent question of whether anti-corruption laws, most prominently the United States Foreign Corrupt Practices Act, will be watered down. Despite the various criticisms of the FCPA, recent instances where companies have appeared to make determined efforts to ignore the FCPA’s prohibitions or attempt to conduct white-wash style investigations potentially as cover for illicit conduct (or at least to save costs if nothing more nefarious), would seem to provide more than enough fodder to assure that no governmental support will likely accrue to efforts to weaken the FCPA or its sister laws and regulations outside the United States.. . .


There’s a review of ‘focus issues,’ a description of all FCPA settlements and criminal matters from 2011 and 2012, a brief discussion of the FCPA’s requirements and penalties, a survey of settlements and criminal matters from 2005 through 2010, and a summary of each DOJ Review and Opinion Procedure Release issued from 1980 till now.

The Summer 2012 FCPA / Anti-Bribery Alert can be downloaded here.

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