For companies that do business outside the United States, the good news is that the number of enforcement actions under the Foreign Corrupt Practices Act tapered off over the last two years, after a dramatic surge in cases from 2007 to 2010.
The bad news is that this tapering does not mean that the government is any less serious about FCPA enforcement. Even though the number of actions has dropped, the U.S. government continues to strengthen and institutionalize its FCPA investigation and enforcement operations.
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