Prosecutions of FCPA cases decrease in 2011.

• Position: ENFORCEMENT - Foreign Corrupt Practice Act

The number of Foreign Corrupt Practice Act enforcement cases dropped in the past year, but U.S. authorities are working more closely with foreign counterparts to rein in illegal activity, according a new report on FCPA enforcement.

The global law firm Shearman & Sterling LLP, in its semi-annual Recent Trends and Patterns in FCPA Enforcement study, found that the number of corporate prosecutions dropped from 20 in 2010 to 16 last year, and penalties against corporations remained stable but relatively low - under $20 million in most cases. That runs counter to the claims of some legislators and commentators that FCPA prosecutions are yielding improved results, the law firm notes.

"It's more than a numbers game," says Philip Urofsky, a Shearman & Sterling attorney based in Washington, D.C., and London, and head of the firm's FCPA and Global Anti-Corruption Practice.

"High fines often result directly from high profits. When a company does not make much money as a result of corrupt conduct, the penalties are significantly lower"

The report also found that American enforcement authorities continued their emphasis on prosecuting individuals last year, charging 18 individuals and taking their cases to trial in several key cases. But Urofsky said a number of these...