NACDL

Increasingly, criminal and regulatory investigations involve companies, individuals, and evidence outside the country. Foreign Corrupt Practices Act (“FCPA”) investigations are at an all-time high.¹ A single FCPA enforcement action settled in 2008 for over $1 billion in fines.² The renewed importance of corruption investigations generally, and FCPA investigations in particular, into both individuals and corporations has been explicitly emphasized by the DOJ,³ the FBI,⁴ and the SEC.⁵ Investigations by foreign governments pursuant to their analogues to the FCPA have risen significantly in prominence as well, evidencing an increased worldwide awareness of, and fight against, corrupt practices.⁶ 

In addition, export controls and economic sanctions are growing more important amid increasing international transactions and regulatory enforcement.⁷ Violations of trade laws can result in corporate and individual criminal liability, civil money penalties, and revocation of export licenses. Antitr