The global anti-corruption compliance landscape continues to evolve as illustrated by recent passage of the UK Bribery Act of 2010, increased cross border governmental enforcement actions, and additional enforcement resources being applied including the noteworthy undercover FBI sting operation.
Since 2008, fines and penalties of approximately $ 2.8 billion were assessed against 36 corporations and 64 individuals by the Securities and Exchange Commission (SEC) and/or US Department of Justice (DOJ), for violations under the Foreign Corrupt Practices Act (FCPA). Although the magnitude is significant, the tidal wave of enforcement actions and associated penalties will not diminish any time soon as regulators target industries operating in emerging markets such as Brazil, Russia, India, and China. Furthermore, the number of individuals prosecuted has jumped from 16 in 2008 to 46 in 2009.
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