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2011 Anti-Corruption Year in Review

After years of headline-grabbing settlements and large, industry-wide investigations of U.S. Foreign Corrupt Practices Act (“FCPA”) violations, 2011 marked a slowdown in the pace of the U.S. enforcment actions.

However, 2011 did have the most FCPA trials in the statute’s hsitory, and several resulted in key judgments, especially those relating to the definition of a “foreign official,” that will impact future enforcement of the statue. A review prepared by The International Law Firm of Fulbright & Jaworski can be found here.