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FCPA Actions Down, Declinations Up

Jaclyn Jaeger | July 17, 2015

Foreign Corrupt Practices Act enforcement actions are off to a slow start this year, likely due to a greater emphasis being placed on FCPA declinations, according to recent analysis from law firm Miller & Chevalier.

Altogether, the Department of Justice and Securities and Exchange Commission resolved eight FCPA enforcement actions in 2015, thus far&mdas;five in the second quarter, and three in the first quarter—the lowest mid-year total in a decade, according to Miller & Chevalier’s analysis. “This slow-down seems to be attributable, in part, to a greater emphasis on declinations by the U.S. enforcement agencies,” the report stated.

The five resolved enforcement actions this quarter include two by the Securities and Exchange Commission and three by the Department...

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