The Justice Department and FCPA Enforcement — Ending the Year with a Bang
The Justice Department is making sure that 2012 will be a very interesting year in FCPA enforcement. Two new and significant trends, which the Justice Department telegraphed, are now a reality. First, and most significantly, the Justice Department is moving its FCPA enforcement program more and more toward the Antitrust Division’s model. What do I mean? In the antitrust context, the Justice Department frequently secures...