2011 marked yet another dynamic year for the Foreign Corrupt Practices Act ("FCPA"), including numerous significant enforcement actions, more trials than in any other year in the history of the statute, and a growing public debate about the policy ramifications of a U.S.-dominated international anti-corruption enforcement field. Those close to the statute can feel the…
On May 17, 2011, the U.S. Securities and Exchange Commission ("SEC") announced its first deferred prosecution agreement ("DPA"). The DPA was with Luxembourg-based Tenaris S.A., a global steel pipe manufacturer and supplier for the energy industry, to resolve alleged violations of the Foreign Corrupt Practices Act ("FCPA").[1] Tenaris, founded in Argentina, is a foreign private…
In anticipation of the April 2011 implementation of the new UK Bribery Act 2010 (the “Act”),[1] on September 14, 2010, the UK Ministry of Justice launched an eight-week consultation regarding the Government’s proposed guidance to commercial organisations on the prevention of bribery. The consultation features the publication of draft guidance on the “adequate procedures” defence…
