Quarterly FCPA Report: Third Quarter 2010

September 30, 2010

William F. Pendergast, Jennifer D. Riddle, Sara A. Murphy, Christina Hardjasa & Russell D. Johnson

The third quarter of 2010 saw another increase in enforcement by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC), compared to the brief lull in enforcement activity in the second quarter of this year. The SEC brought successful actions against four companies and three individuals. The DOJ indicted two new individuals in connection with Foreign Corrupt Practices Act (FCPA) violations and resolved cases against four companies. Seven individuals previously charged by the DOJ were sentenced, including Gerald and Patricia Green, who had been awaiting sentencing since their conviction in September 2009. Three individuals pleaded guilty to charges resulting from the DOJs FCPA investigations, including Richard Bistrong, the key intermediary in the FCPA indictment of 22 individuals in the first quarter of this year. Finally, James Tillery, wanted in connection with FCPA violations in Nigeria, was detained in Nigeria and may be extradited to the United States.

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