FCPA 2021 Year In Review
The Biden administration took office in January 2021, announcing aggressive and sweeping anticorruption initiatives to tackle corruption around the world, labeling corruption a national security priority, and signaling a "surge" in corporate and individual enforcement. But the debilitating COVID-19 pandemic, coupled with the turnover in DOJ and SEC leadership, led to the lowest corporate Foreign Corrupt Practices Act ("FCPA") enforcement figures in the past 15 years. Nevertheless, the Biden administration's enforcement priorities began to take shape. Last year, the Deputy Attorney General announced enforcement policy revisions, and DOJ and SEC officials signaled a more aggressive posture toward corporate and individual FCPA enforcement. Meanwhile, the DOJ and the SEC continued to coordinate FCPA resolutions with their foreign counterparts, and the SEC made two sizeable awards to FCPA whistleblowers.
This White Paper reviews 2021 FCPA enforcement and describes what lies ahead.
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