On January 25, 2011, officials from the US Justice Department and the Securities and Exchange Commission reiterated their commitment to aggressive FCPA enforcement for the current year. Speaking at the FCPA Boot Camp in Houston, Texas, Nathaniel Edmonds, Assistant Chief of the Fraud Section at the Department of Justice, and Jason Rose, head of Enforcement for the SEC in the Texas region, predicted that the number of joint investigations between the DOJ and the UK’s Serious Fraud Office would increase this year.

With the UK Bribery Act 2010 scheduled to become effective in April, Edmonds emphasized that the number of investigations and prosecutions will increase. He also specifically noted that there are more prosecutors assigned to FCPA cases and that the FBI maintains a dedicated squad of agents for FCPA investigations.

Speaking on the issue of compliance programs, Edmonds noted that to ensure overall compliance, the Justice Department would not credit “paper” programs but would evaluate programs based on the level of follow-though, commitment and attention shown. Edmonds warned companies to design and implement meaningful and legitimate compliance programs. Finally, Edmonds indicated that there will be several big FCPA enforcement announcements this spring and alluded to the conclusion of several long-standing investigations.

For inquires related to this Legal Update, please contact Michael L. Volkov at +1 202 263 3288.

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