The SEC's
creation in January 2010 of a specialized Foreign Corrupt Practice unit focused on violations of the FCPA and led by Cheryl J. Scarboro has been well-documented and discussed. Far less publicized, however, has been the SEC's opening of a San Francisco unit that is solely dedicated to the enforcement of the FCPA.
Last month, the San Francisco Daily Journal
reported that the SEC's San Francisco Regional Office was putting the "finishing touches" on the new FCPA unit, which is part of the national SEC unit announced in January. The unit is headed up by Tracy L. Davis, the assistant regional director, who stated that "[t]he fact that we have a significant presence of companies in Silicon Valley who do business internationally, specifically in Asia, makes us well-suited for addressing these kinds of issues. That's one of the reasons why San Francisco is a particularly good location for an FCPA unit."