Recent actions announced by the DOJ and SEC during the first quarter of 2016 suggest that this year may be a significant one for FCPA 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.

Download the full Foreign Corrupt Practices Act alert.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.