In this article, James Tillen, Marc Bohn,* and Leila Babaeva* discuss developments in Foreign Corrupt Practices Act (FCPA) enforcement activity in the first quarter of 2012. According to the authors, the level of activity is roughly on par with enforcement activity over the same time period last year and remains significantly down from the record heights reached in 2010. In their analysis, the authors discuss individual defendants, the recent focus on the healthcare industry, merger and acquisition activity, FCPA reform and monitorships across the beginning of 2012.

*Former Miller & Chevalier attorney