Recent actions announced by the U.S. Department of Justice and the U.S. Securities and Exchange Commission during the first quarter of 2016 suggest that this year may be a significant one for Foreign Corrupt Practices Act enforcement. These cases indicate that even as the DOJ has renewed its focus on individuals, it continues to pursue large cases with corporations — and that the SEC continues to broadly define a "thing of value" under the FCPA. These settlements also underscore the importance of having a strong and effective compliance program, as well as cooperating with the government during investigations.
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Originally published by Law360
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