The Foreign Corrupt Practices Act juggernaut appeared to get off to a slow start this year. Depending on how one classifies cases, there was either one enforcement action or none in the first quarter of 2013, according to a report from Miller & Chevalier.

But appearances can be deceiving. And in this case, it seems they were. That statistic is more a matter of timing than anything else, according to John Davis, coordinator of the firm’s FCPA and international anticorruption practice group.

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