One of the World’s Most Feared Enforcement Tools

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The History of FCPA Enforcement, Part 2

In Part 1 of this two-part series on the history of the enforcement of the FCPA, Anne Eberhardt discussed some of the factors that led to its creation. In this second part, she describes how the FCPA evolved into one of the most feared law enforcement tools.

The FCPA was signed into law in December of 1977. During the 40 years that followed, ending in 2017, the SEC and the U.S. Justice Department collected about $10.6 billion in fines and penalties under more than 520 enforcement actions. About $10.3 billion – or…

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