Anti-corruption enforcement activity is continuing to increase. Underscoring this trend is the fact that there are approximately 35 defendants now awaiting trial on corruption charges in the U.S. and that DOJ ranks have grown to over a dozen attorneys dedicated solely to prosecuting corruption cases.

Moreover, 63 percent of respondents to a Deloitte annual "Look Before You Leap" survey of corporate executives, investment bankers, private equity executives and hedge fund managers reported that FCPA issues caused their companies to renegotiate or abandon planned business relationships, mergers or acquisitions over the last three years.  

Ed Rial of Deloitte's FCPA consulting practice said, "[i]ncreased governmental crackdowns on corporate corruption and foreign bribery issues are dramatically changing the playing field for potential transactions. As such, companies are either reevaluating the costs and benefits of these deals, or are outright scuttling those that present unacceptably high risks."