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Quarterly FCPA Report: Fourth Quarter 2012

February 07, 2013

By THE GLOBAL COMPLIANCE AND DISPUTES PRACTICE GROUP

The DOJs and SECs activities in the fourth quarter highlight the importance of a robust corporate compliance program and prompt investigation of potential violations. While the fourth quarter was dominated in large part by the release of the government's long-awaited FCPA guidance, the increasing willingness of defendants to challenge the FCPA's reach may have greater consequences with regard to the FCPA's role as a global enforcement mechanism.