Quarterly FCPA Report: Fourth Quarter 2011
By THE GLOBAL COMPLIANCE AND DISPUTES PRACTICE
This quarter continued the trend of active FCPA enforcement, with the DOJ winning a historic prison sentence and reaching several settlements with high profile corporations. Though the sum total of corporate fines, penalties and disgorgement may have dropped in 2011 ($508.6 million, down from $1.8 billion in 2010), the DOJ has aggressively pursued enforcement actions against individuals. While there has been some push back from the courts against the DOJs tactics, the DOJ and the SEC continue to zealously pursue both corporate and individual violators of the FCPA.