The Foreign Corrupt Practices Act in the Ultimate Year of Its Decade of Resurgence

Abstract

The Foreign Corrupt Practices Act (FCPA) was enacted in 1977, yet FCPA enforcement was largely non-existent for most of its history. But during the past decade, enforcement agencies resurrected the FCPA from near legal extinction. FCPA enforcement activity in 2009, the ultimate year in the decade of the FCPA's resurgence, suggests that FCPA enforcement will remain a prominent feature on the legal landscape throughout this decade. After providing a brief overview of the FCPA and FCPA enforcement, this Article highlights FCPA issues and trends from the 2009 enforcement year and provides a glimpse of the road ahead as the FCPA enters a new decade.