Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual...more
1/31/2024
/ Acquisitions ,
Anti-Bribery ,
Anti-Corruption ,
Clawbacks ,
Compliance ,
Cooperation ,
Data Protection ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Priorities ,
Enforcement Statistics ,
Executive Compensation ,
FCPA Corporate Enforcement Policy (CEP) ,
FEPA ,
Foreign Corrupt Practices Act (FCPA) ,
Latin America ,
Mergers ,
Pilot Programs ,
Safe Harbors ,
Securities and Exchange Commission (SEC) ,
Self-Reporting ,
Voluntary Disclosure
While Foreign Corrupt Practices Act (FCPA) enforcement activity has not come close to returning to the heights seen a few years ago, 2022 reflected significant increases from the prior year in both the number of cases against...more
2/10/2023
/ Anti-Bribery ,
Anti-Corruption ,
Bribery ,
CFTC ,
Compliance ,
Cooperation ,
Corporate Crimes ,
Corporate Criminal Fines ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward...more
1/28/2022
/ Anti-Corruption ,
Biden Administration ,
Bribery ,
Compliance ,
Cooperation ,
Corruption ,
Cross-Border ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Government Investigations ,
Securities and Exchange Commission (SEC) ,
White Collar Crimes
As was true in many areas of the law, Foreign Corrupt Practices Act (FCPA) enforcement in 2020 - and anti-corruption enforcement more generally - was affected by the COVID-19 pandemic, but perhaps not as much as was initially...more
2/1/2021
/ Bribery ,
Compliance ,
Corporate Investigations ,
Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Guidance ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC)
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more
1/18/2019
/ Anti-Bribery ,
Anti-Corruption ,
Brazil ,
Bribery ,
Chief Compliance Officers ,
China ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Corporate Investigations ,
Corruption ,
Credit Suisse ,
Criminal Investigations ,
Criminal Prosecution ,
Declination ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Enforcement Statistics ,
Foreign Corrupt Practices Act (FCPA) ,
Panasonic ,
Petrobras ,
Securities and Exchange Commission (SEC) ,
Strategic Enforcement Plan ,
Voluntary Disclosure ,
Whistleblowers ,
Yates Memorandum
The past year was consequential for FCPA enforcement in numerous respects, including blockbuster penalties, new policy initiatives, and the SEC’s first DPA with an individual for FCPA violations. In April 2016, the DOJ’s...more
2/8/2017
/ Chief Compliance Officers ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Deferred Prosecution Agreements ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
Federal Pilot Programs ,
Federal Sentencing Guidelines ,
Foreign Corrupt Practices Act (FCPA) ,
Non-Prosecution Agreements ,
Popular ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure
I. Introduction: Enforcement Trends and Priorities -
Among other significant developments, 2015 saw the U.S. Department of Justice (the “DOJ” or the “Department”) document a policy priority of holding individuals...more
2/3/2016
/ Bank of New York (BNY) Mellon ,
BHP Billiton ,
Blocking Statutes ,
Bristol-Myers Squibb ,
Compliance ,
Cooperation ,
Corporate Counsel ,
Criminal Prosecution ,
Deferred Prosecution Agreements ,
Enforcement Statistics ,
FLIR System ,
Foreign Corrupt Practices Act (FCPA) ,
Hitachi ,
Olympics ,
Strict Liability ,
Yates Memorandum