Shearman & Sterling's Philip Urofsky and Dan Newcomb were featured in a March 29 story in Law360, titled "FCPA Enforcement Actions Increasing In Scale: Report," which showcases many of the findings in Shearman & Sterling's March 2010 FCPA Digest.

Commenting on the recent string of highly visible actions, such as the $447 million fine levied against BAE Systems PLC and the roundup of more than 20 business executives in Las Vegas, Urofsky said, "In some ways, 2009 can be viewed as the calm before the FCPA storm ... Unlike the prosecutions of Siemens and Halliburton/KBR in late 2008 and early 2009, which resulted in record-breaking penalties of $1.5 billion and $600 million, respectively, many of the corporate cases brought in 2009 involved smaller companies and smaller fines." Yet, this this trend has not continued into 2010, he added. Instead, since the beginning of the year, Technip, Daimler AG, Alcatel-Lucent and Eni SpA have all disclosed they would pay fines of more than $200 million to resolve allegations that they bribed foreign officials in violation of the FCPA.

And while corporate matters took a dip in the past year, Newcomb, who founded Shearman & Sterling's FCPA practice, noted that this does not mean that corporations should stop being cautious. He said, "Companies shouldn't be lulled into a fall sense of security that the government is any less interested in or committed to combating anti-corruption."

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