Final Count for 2012 Declinations

The FCPA Blog
01.24.13
In this article, Marc Alain Bohn discusses the final count of declinations in 2012. According to Bohn, if one uses the broader definition of 'declination', 2012 saw a notable increase in the number known declinations by the DOJ, while the number of known declinations by the SEC kept pace with levels from 2010 and 2011. Whether the overall uptick is due to an actual increase in declinations by the agencies or simply more declination decisions being disclosed - either by the agencies or the companies involved - is unclear.
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