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Quarterly FCPA Report: First Quarter 2012

The first quarter of 2012 presented a mixed bag for the U.S. DOJ in FCPA enforcements. The DOJ dealt with setbacks such as a second mistrial in the Shot Show case and the eventual dismissal of the entire case, including the dismissal of the indictments of three individual defendants who pleaded guilty in 2011. On the other hand, the DOJ obtained a guilty plea from Patrick Joseph and a conviction against Jean Rene Duperval in the Haiti Teleco case. With the filing of a second superseding indictment, the Haiti Teleco case replaces the now-defunct Shot Show case as having the most individual (non-corporate) defendants in history. Despite criticisms leveled against the DOJ relating to recent mistrials and acquittals, the DOJ and the U.S. SEC announced settlements with criminal fines totaling more than $98 million this quarter, an increase of over $20 million from last quarter.

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