Client Alert

Quarterly FCPA Report

April 07, 2010

William F. Pendergast, Jennifer D. Riddle, Sara A. Murphy, Christina Hardjasa & Russell D. Johnson

I. Introduction

2010 is already shaping up to be another significant year for enforcement of the U.S. Foreign Corrupt Practices Act (FCPA). The U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) appear to be pursuing a course of aggressive investigation and prosecution both within the United States and through cooperation with foreign authorities. Companies that voluntarily disclose their FCPA violations continue to reap significant benefits when dealing with U.S. authorities. As the increased enforcement stance of U.S. law enforcement continues, effective FCPA compliance programs should be a priority for any entity doing business outside of the United States.

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