The Department of Justice (DOJ) continues to aggressively enforce the Foreign Corrupt Practices Act (FCPA). In November 2010, Lanny Breuer, the head of the Criminal Division at DOJ, hailed the Department's collection of more than $1 billion in FCPA criminal penalties in the previous 12 months. At the same time, he boldly proclaimed the beginning of a "new era" for FCPA enforcement: "I'm proud to say that our FCPA enforcement is stronger than it's ever been and getting stronger."
1 Indeed, 2010 set new records for FCPA cases, with the government bringing more than 70 actions.
2 Companies and individuals are more than right to be concerned about this "new era."
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