FCPA Enforcement Trends

Compared to the blistering pace set by U.S. authorities in previous years, 2012 saw a decline in Foreign Corrupt Practices Act (FCPA) enforcement. This downturn, however, is a slight blip on the radar, attributable to, among other things, vast government resources being poured into the comprehensive FCPA Resource Guide released in November and trench warfare being waged by both the DOJ and the U.S. Securities and Exchange Commission in numerous venues across the country. In terms of industries targeted, half of the 12 corporate enforcement actions of 2012 involved allegations against health care companies or health care units of companies.