The u. S. Foreign corrupt practices act implications for international distributors

Increasing enforcement - both in quantity and magnitude

• Increasing enforcement - both in quantity and magnitude
• ▪ SEC focuses on accounting/reporting violations, SOX
• DOJ lead enforcer on anti-bribery provisions
• ▪ 2008: highest number of enforcement actions ever
• 82 corporations with open investigations with SEC/DOJ in 2008
• ▪ Increase in SEC, DOJ, FBI staff dedicated to FCPA enforcement
• Enforcement Focus: 2008,continuing into 2009
• ▪ Identified industries w/ problematic track records
• Energy, technology, medical devices, defense contracting, infrastructure
• ▪ Individual offenders: increased enforcement against individuals
• FBI stated emphasis is to “convict individuals”

• Enforcement