After years of headline-grabbing settlements and large, industry-wide investigations of U.S. Foreign Corrupt Practices Act ("FCPA") violations, 2011 marked a slowdown in the pace of the U.S. enforcement actions. However, 2011 did have the most FCPA trials in the statute's history, and several resulted in key judgments, especially those relating to the definition of a "foreign official," that will impact future enforcement of the statue.

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