Quarterly FCPA Report: Second Quarter 2012
By THE GLOBAL COMPLIANCE AND DISPUTES PRACTICE GROUP
Although the U.S. Department of Justice ("DOJ") encountered setbacks this quarter in court, there is no indication that it has slowed its ever-increasing enforcement of the Foreign Corrupt Practices Act ("FCPA"). The Wal-Mart investigation has amplified the public's focus on anti-corruption enforcement efforts and may have an effect on efforts to reform the law. With new guidance from the DOJ expected this year, companies will likely gain better insight into the government's interpretation of the FCPA's scope, as well as the factors used by the DOJ in making its enforcement decisions.