Has enforcement really slowed down? Maybe not

Following publication last week of the Corporate Investigations List, a long-time FCPA Blog reader sent the following comment:

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One thing that has not gotten much discussion is the possibility that the apparent slowdown in FCPA enforcement may be due to the spike in declinations. There have been at least twelve in the last three quarters and half of those were this quarter. That’s a pretty good amount if they were viewed as enforcement actions. There may be a push inside the DOJ and SEC to clear the backlog of the ‘little’ cases. As you know these things big or small tend to drag on for years.

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That’s great insight about the nature of enforcement actions and declinations, and the size of the Corporate Investigations List.

We’ll see if the trend toward more declinations continues this quarter and for the rest of 2013.