Quarterly FCPA Report: Fourth Quarter 2010

January 18, 2011

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

The fourth quarter of 2010 concluded a record year in FCPA cases and clearly demonstrated the U.S. Enforcement Agencies emphasis on conducting industry-wide sweeps with respect to the Foreign Corrupt Practices Act (FCPA). Notably, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) settled long-running and wide-ranging investigations of companies in the oil and gas sector involving improper payments made both directly and indirectly through freight forwarders. These investigations led the DOJ and SEC to set new records in FCPA enforcement for the largest number of corporations settling FCPA actions with the Agencies at one time and for some of the largest fines imposed in an FCPA action.

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