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2010 FCPA Enforcement Shatters Records

Melissa Klein Aguilar | January 4, 2011

Multinational companies beware: That promised new era of Foreign Corrupt Practices Act enforcement has already arrived.

The number of FCPA enforcement actions jumped 85 percent in 2010, shattering the prior record set in 2009, according to data tracked by the law firm Gibson Dunn & Crutcher. The Department of Justice and the Securities and Exchange Commission brought a combined 74 FCPA enforcement actions in 2010, far surpassing any prior year in the statute's 33-year history.

The SEC brought 26 enforcement actions, beating a previous high of 20 actions in 2007, while the DoJ filed 48 cases, demolishing 2009's record 26 actions, according to GDC's 2010 Year-End FCPA Update. Eight of the top 10 monetary settlements in FCPA history occurred in 2010....

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