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Foreign Corrupt Practices Act

The U.S. government has stepped up enforcement of the Foreign Corrupt Practices Act (FCPA). This new emphasis focuses not only on the anti-bribery provisions of the FCPA administered by the Department of Justice, but also on the books, records and accounting provisions of the statute administered by the Securities and Exchange Commission. Standards and expectations regarding compliance are changing and becoming more draconian. Recent examples include the current investigations and penalty proceedings by both agencies in relation to the Iraq Oil for Food program. We have been actively involved in internal investigations on a global basis and in negotiating major criminal cases before the Department of Justice and Securities and Exchange Commission, as well as in representing clients in the World Bank’s Voluntary Disclosure Program.