By all accounts, 2007 was a monumental year in Foreign Corrupt Practice Act enforcement. The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) filed an ever-increasing number of criminal and civil FCPA actions, respectively. One of those criminal cases was resolved with the imposition of a record-setting fine ($26 million), and parallel criminal and civil cases filed against another defendant resulted in the largest combined fine and civil penalty ever ($44 million).

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