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Quarterly FCPA Report: Third Quarter 2012

November 21, 2012

By GLOBAL COMPLIANCE & DISPUTES PRACTICE GROUP

The DOJs and SECs activities in the third quarter signal that the enforcement authorities require continued diligence from U.S. companies to ensure their monitoring programs are sufficient to identify and correct potentially improper actions. In the fourth quarter, the DOJ also released its long-awaited guidance on several contested provisions of the FCPA.

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