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Our team has unsurpassed experience in counseling and defending U.S. and foreign companies and individuals in matters relating to the U.S. Foreign Corrupt Practices Act and similar anti-corruption laws. We are frequently contacted when a potential corruption issue arises, and are go-to counsel for investigations and enforcement proceedings before the U.S. Department of Justice (DOJ), the Securities & Exchange Commission (SEC) and the Multilateral Development Banks, including the World Bank. In addition, we advise clients considering transactions in high-risk markets or with business partners with high anti-corruption risks. We also counsel clients who are designing compliance programs and in conducting risk assessments.

FCPA Enforcement and Anti-Corruption Developments: 2020 Year In Review

January 22, 2021 Download PDF

Despite the significant obstacles presented by COVID-19, the DOJ and the SEC assessed a record-breaking total in corporate FCPA penalties, and foreign authorities assessed a similar amount. The number of corporate FCPA enforcement actions resolved by the DOJ and the SEC remained comparable to prior years, while the number of individual prosecutions dropped considerably, perhaps due to challenges posed by the pandemic. The DOJ and the SEC also announced several policy revisions intended to increase transparency and consistency in FCPA enforcement. In this alert, we reflect on the year’s most significant anti-corruption and FCPA developments.

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