The United States Department of Justice (US DOJ) under the Obama Administration has ratcheted up Foreign Corrupt Practices Act (FCPA) enforcement even beyond what the Bush Administration started in recent years.

The US DOJ, especially through its Criminal Division Chief, Lanny Breuer, has been vociferous about what it intends to do next on FCPA enforcement.

The United States Securities and Exchange Commission (US SEC), long responsible for investigating and enforcing the “books and records” or accounting provisions of the FCPA, has become a centre of activity as well after years of being less proactive on this topic.

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