This year has been a watershed in terms of Canada’s enforcement of its Corruption of Foreign Public Officials Act (“CFPOA”):

• In January 2013, a record fine of CAD 10.35 million (USD 10.27 million) was imposed on Griffiths Energy International (“Griffiths Energy”), now known as Caracal Energy Inc., for paying a USD 2 million bribe in order to secure lucrative oil contracts in the Republic of Chad. This was the largest fine Canadian authorities have secured in a foreign corruption case, and Griffiths Energy was the first company to self-report international bribery...