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Embedding Compliance

By Jeffrey Hessekiel and Alex Toy

The year 2012 was another banner year for Department of Justice (DOJ) officials charged with prosecuting corporate enforcement actions. The DOJ recovered $4.9 billion from False Claims Act cases, the most ever in a single year.

Although there was a small relative decrease in Foreign Corrupt Practices Act (FCPA) cases, the head of the DOJ's Criminal Division commented that “robust FCPA enforcement has become part of the fabric of the Justice Department” and a “reality that companies know they must live with and adjust to.” To his point, consider Wal-Mart, which has been accused of civil and criminal violations of the FCPA for allegedly bribing officials in Mexico to expedite the rapid construction of new stores, including one on top of an important archeological site.

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