A LITTLE LESS CONVERSATION, A LITTLE MORE ACTION: EVALUATING AND FORECASTING THE TREND OF MORE FREQUENT AND SEVERE PROSECUTIONS UNDER THE FOREIGN CORRUPT PRACTICES ACT From: Fordham Journal of Corporate & Financial Law | Date: March 1, 2007| Author: Marceau, Justin F | Copyright Fordham Journal of Corporate & Financial Law 2007. Provided by ProQuest LLC.Copyright information

In the wake of increasingly common, creative, and severe prosecutions under the Foreign Corrupt Practices Act ("FCPA"), scholars and practitioners must acknowledge that the time for talk-i.e., non-punitive voluntary disclosures and abstract debate-has given way to an era of aggressive enforcement actions by the Department of Justice and the securities Exchange Commission. The bare numbers tell much of the story: the Department of Justice has initiated four times more prosecutions over the las...

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