The last several years have seen a dramatic increase in enforcement of the U.S. Foreign Corrupt Practices Act ("FCPA"), which, as most AMCHAM members will know, is a broad law that criminalizes corrupt payments to foreign officials. In the prior decade, the Department of Justice ("DOJ") did not file a single FCPA case until 2002; but last November, the DOJ announced there were more than 130 open FCPA cases. That number is expected to increase.

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