Gibson, Dunn’s 2009 Year End Foreign Corrupt Practices Act Update was recently released and it’s available here. I picked FCPA prosecutions as one of 2009’s most important developments in this area of law and the firm’s update reflects the heightened attention to the FCPA. The firm’s update begins:
“One can say without exaggeration that this past year was probably the most dynamic single year in the more than thirty years since the FCPA was enacted.” So began Assistant Attorney General Lanny Breuer in a recent recap of 2009 Foreign Corrupt Practices Act (“FCPA”) enforcement. Indeed, for the fourth time in the last five years, the Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”), the statute’s dual enforcers, set a record by bringing more FCPA prosecutions than in any prior year in the FCPA’s history.