Taking the podium at the National Conference on the Foreign Corrupt Practices Act (FCPA) in November 2010, Assistant Attorney General Lanny Breuer declared, "We are in a new era of FCPA enforcement." This proved to be true in 2011 - a year that saw criminal FCPA trials, a number of other significant enforcement actions, and the first judicial guidance on what constitutes a "foreign official" under the statute.
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