In this article, Marc Alain Bohn and Michael Skopets discuss Foreign Corrupt Practices Act (FCPA) enforcement trends in the second quarter of 2015, in particular, the low level of FCPA enforcement to date. "The second quarter of 2015 saw relatively few resolved enforcement actions brought under the Foreign Corrupt Practices Act, which followed a similarly slow first quarter of the year. Including the five actions this past quarter, U.S. enforcement authorities brought eight resolved enforcement actions through June, the lowest midyear total in a decade," the authors said. "Caution should be taken when making inferences about current enforcement levels, though, as the statistics for any given quarter are not necessarily indicative of larger trends and the pace of enforcement frequently picks up as the year goes on."
Bohn and Skopets highlight notable FCPA enforcement actions and declinations across the past four months and discuss related developments in the FCPA field. This article is an excerpt from Miller & Chevalier's FCPA Summer Review 2015, which is available here.