2021 FCPA Enforcement & Compliance Review

January 5, 2022, 12 Noon EST

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2021 Sanctions Enforcement & Compliance Review

January 12, 2022, 12 Noon EST

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With the continuing impact of COVID-19 and economic disruptions, the Justice Department and the SEC continued to push FCPA enforcement. DOJ and the SEC repeated broad statements confirming continued aggressive enforcement programs. However, DOJ and SEC’s record revealed a slow down in corporate enforcement actions.

The new Administration continues to push anti-corruption initiatives, including the release of its Strategy to Counter Corruption, and has promised a more aggressive approach to white collar crime enforcement, including the FCPA. Deputy Attorney General Lisa Monaco previewed this new enforcement push and specifically mentioned that more corporate compliance monitors will be imposed in the future. Despite the uneven record, FCPA criminal enforcement against individuals continued at a steady pace and portends even more cases in 2022. 

With the growing use and reliance on economic sanctions as a policy lever, the Justice Department and the Office of Foreign Asset Control continued their aggressive enforcement of economic sanctions. OFAC and DOJ joined together in the SAP sanctions enforcement case, which established significant new requirements for sanctions compliance programs. OFAC continues to raise compliance expectations, hold individual and corporate actors accountable, and pointing to specific lessons learned.   

In this two-part webinar (January 5 and January 12, 2022), Michael Volkov will review 2021 FCPA and Sanctions enforcement and compliance trends.

Session I will focus on the FCPA and Session II will focus on Sanctions enforcement and compliance issues.
A recording of each session will be made available via Volkov Law TV.