The Foreign Corrupt Practices Act may have been in the government’s deep freezer for most of its 30-year history, but regulators are heating up fresh new helpings of it these days.
Enforcement actions under the anti-bribery statute are bustling, both in sheer numbers and in innovative new applications of the law. According to an analysis by the law firm Gibson, Dunn & Crutcher, actions brought by the Justice Department and Securities and Exchange Commission went from two in 2003 to at least 20 filed in the last 18 months. Nine actions have been filed so far this year, on pace to exceed the 15 actions in all of 2006.
