In the same year the Department of Justice and Securities and Exchange Commission produced guidance on the Foreign Corrupt Practices Act, there was also a slow-down in FCPA enforcement actions, according to some year-end tallies from law firms.
“It was in some ways a quieter year on the corporate front,” says Shearman & Sterling partner Philip Urofsky, whose firm published its “Recent Trends and Patterns in FCPA Enforcement.”
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