The Ultimate Guide to FCPA Activity in 2013

From attorneys at Shearman & Sterling, an impressive 744-page digest of 2013 Foreign Corrupt Practices Act cases, official communications, and trends:

“Last year, we noted that 2012 had been ‘a fairly slow time’ in terms of corporate enforcement actions, with twelve enforcement actions against corporations. 2013 was slower still, with only nine corporate enforcement actions. There was a steep increase in corporate fines, however, and enforcement against individuals saw a marked increase, from five in 2012 to sixteen in 2013—eight of whom pleaded guilty.

Among the highlights:

  • Over $720 million in penalties in 2013, and the average penalties ($80 million) and the adjusted average ($28 million) were both considerably up from previous years;
  • Significant number of new cases against individuals;
  • Surge in ‘hybrid’ monitors, with an independent monitor’s term of 18 months followed by 18 months of self-monitoring;
  • Continued aggressive theories of jurisdiction and parent-subsidiary liability; and
  • Adoption of deferred prosecution agreements in the U.K., albeit with substantially more judicial involvement than in the U.S.”

Read it in full below:

[Link: January 2014 FCPA Digest]

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