Vigorous, Expanded Enforcement of the US Foreign Corrupt Practices Act

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1. As explained in the Guide, the US Foreign Corrupt Practices Act of 1977 ("FCPA") broadly prohibits improper payments to foreign officials.
   
   
2. In our FCPA work this year, we have observed a number of trends that we believe will have critical legal and practical implications for multinational entities with business touching on the US.  These include:

(a) Heightened, aggressive enforcement by both the US Department of Justice (DOJ) and the Securities and Exchange Commission (SEC).  The rate of cases has more than doubled in recent years - a trend that we expect will continue;

(b) Exponential increases in the fines being levied - including a recent, record-breaking $1.3 billion fine levied against Siemens; and

(c) Increased international assistance in enforcing the FCPA.

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