Understanding and Preparing for an “Industry Sweep” under the Foreign Corrupt Practices Act

By Zack Harmon and Amelia R. Medina, King & Spalding LLP

I.Introduction

In recent years, the Department of Justice (DOJ) and Securities & Exchange Commission (SEC) have embraced the use of so-called “industry sweeps” as an enforcement tool against suspected violations of the Foreign Corrupt Practices Act (FCPA).