White Collar Crime Report, Vol. 7, 2012
8 Pages Posted: 30 Jan 2012
Date Written: January 27, 2012
For most of the Foreign Corrupt Practices Act's history, key decisions concerning its enforcement and direction were made behind closed doors around conference room tables in Washington, D.C. While many enforcement decisions and procedures remain opaque, 2011 witnessed the most intense year of public scrutiny in the FCPA's history.
This article, in addition to providing a brief overview of the 2011 enforcement year, details the scrutiny the FCPA was subjected to in the past year. This scrutiny reveals that as the FCPA nears its 35th year, basic legal and policy questions remain as to the purpose, scope, and effectiveness of the law.
Keywords: FCPA, Foreign Corrupt Practices Act, Voluntary Disclosures, Non-Prosecution Agreement, Deferred Prosecution Agreement
Suggested Citation: Suggested Citation
Koehler, Mike, 2011 Foreign Corrupt Practices Act Year in Review: Scrutiny, Reform, and Individual Prosecutions are Key Issues (January 27, 2012). White Collar Crime Report, Vol. 7, 2012. Available at SSRN: https://ssrn.com/abstract=1992616