• In 2004, the DOJ collected about $11 million in criminal fines. In 2009 and 2010 combined, the DOJ collected nearly $2 billion in criminal fines.

  • The FBI has trained a special investigative unit for FCPA violations.

  • FCPA enforcement officials currently have more than 150 criminal and 80 civil investigations underway.

  • New FCPA whistleblower provisions increase risks.

  • In 2010, 52 individual businesspeople were indicted, sentenced, or convicted and are awaiting sentencing for FCPA violations.

  • Enforcement officials resolved 6 FCPA enforcement actions in 2002. In 2010, they resolved 71.

  • In 2010 alone, five FCPA settlements exceeded $100 million.

  • The amount of FCPA penalties tripled between 2009 and 2010.

  • Individuals are facing significant FCPA fines and jail time for authorizing improper payments.

  • FCPA actions are increasingly brought against small and medium-sized companies as well as high-profile multinational corporations.


What is an anti-corruption compliance program?

A robust anti-corruption compliance program is essential to your company’s bottom line. A modest investment in an effective program upfront can prevent or mitigate expensive and burdensome issues on the backend.

Compliance Programs:

To implement an effective compliance program, companies should, at a minimum: conduct regular anti-corruption risk assessments; enact policies and procedures and internal controls; vet agents and partners; schedule trainings of employees; provide reporting hotlines; and create monitoring and review mechanisms.

Enforcement Perspectives:

Enforcement officials stress that there is no “one size fits all” model for compliance programs and that “check the box” programs are inadequate. Programs should be tailored to the company, comprehensive, communicated clearly, and enforced. They must have real substance and “top down” commitment from senior management. They should address the most sensitive areas of your business, such as the use of consultants, agents and representatives. Companies must continually evaluate their programs to ensure they are dynamic, not static

Learn more about the ways in which Matteson Ellis Law, PLLC, can assist you here.

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