White-collar and compliance practitioners have noted the increased enforcement of the Foreign Corrupt Practices Act (FCPA), 15 U.S.C. §§ 78dd-1, et seq. by the U.S. Department of Justice (DOJ) in the past decade. Recent years have seen a rise in the number of enforcement actions, a growth in the amount of the fines and disgorgements sought against individuals and corporations, and an increased willingness by the DOJ to take FCPA cases to trial. The latest trend in FCPA enforcement may be an expansion of these increased efforts into a previously untouched industry—entertainment. The recent conclusion of an FCPA enforcement action against a Hollywood couple presents a stark warning to an industry that was not traditionally on the FCPA’s radar.
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