FCPA Enforcement and Compliance Review

January 9, 2024, 12 Noon EST

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Sanctions Enforcement and Compliance Review

January 16, 2024, 12 Noon EST

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Start the New Year off right — review 2023 FCPA enforcement and compliance on January 9, 2024, and then one week later, on January 16, 2024, review 2023 sanctions enforcement and compliance.

FCPA: For the Justice Department and the SEC, 2023 was a slow year in FCPA enforcement. 

Despite promises of aggressive enforcement, DOJ and the SEC failed to achieve increases in FCPA enforcement. DOJ and the SEC issued no blockbuster enforcement actions or settlements. The SEC’s number of enforcement actions was steady and eclipsed its 2022 number by one. Equally significant was DOJ’s reduction in individual criminal prosecutions, thereby raising legitimate questions as to its ability to deliver on its promise of aggressive enforcement against individual FCPA violators. 

While 2023 was a slow enforcement year, DOJ dedicated significant resources to issuance of new policy statements encouraging voluntary disclosures, incentivizing clawbacks, elevating compliance programs and offering new safe harbors for mergers and acquisitions.  

Sanctions: The Justice Department and the Office of Foreign Assets Control had a big year in 2023. Criminal and civil enforcement continue to increase. DOJ has warned corporations that aggressive sanctions enforcement actions are coming — to that end, DOJ assigned 25 new prosecutors to the National Security Division to execute on its promise. Meanwhile, OFAC had a record year in collecting $1.539 billion in penalties, largely the result of two blockbuster settlements — British American Tobacco and Binance, the cryptocurrency exchange.

In this two-part webinar (January 9 and January 16, 2024), Michael Volkov will review 2023 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.