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White-Collar Crime
By Multiple Authors
FCPA Enforcement Update
DOJ Targets the Health Care Industry
Enforcement of the Foreign Corrupt Practices Act (“FCPA”)1 has increased over the past several years. In 2009 alone, the Department of Justice (“DOJ”) and the Securities Exchange Commission (“SEC”) announced enforcement actions and resolutions against 11 corporations and 33 individuals. The dollar value of the corporate enforcement actions in 2009 exceeded $644 million. Continued aggressive enforcement is expected, and 2010 opened with the announcement of a “sting” operation in which 22 individuals in the military law enforcement products industry were arrested and indicted.2 This was the first large scale use of undercover law enforcement techniques in an FCPA case, and Assistant Attorney General Lanny A. Breuer warned that more will follow.3
Health Care Companies To Be Targeted
Against this backdrop of increased enforcement, the DOJ leadership recently announced on more than one occasion that it is targeting the health care i
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