Clifford Chance
The Asia Pacific Top Ten FCPA Enforcement Actions of 2012
24 January 2013
The Asia Pacific region remained a hotspot for US anti-corruption enforcement authorities in 2012. Six of the twelve corporate Foreign Corrupt Practices Act (FCPA) settlement agreements in the past year involved business operations in that region. In addition to these six resolutions, we include some prosecutions against individuals which confirm the enforcement focus on the decision makers who authorize bribery.
Finally, we include some significant declinations, as the agency press releases and company disclosures discussing the factors underlying the decision not to charge can provide as much guidance as the settlement agreements.
