The FCPA Year in Review — More of the Same with Some Twists (Part I of III)
With the end of the Biden Administration, it is hard to identify a consistent theme relating to FCPA enforcement. On the one hand, the Biden Administration talked a big game, elevating the anti-corruption fight as a national security priority and promising even more aggressive FCPA enforcement than the prior Trump Administration. At the same time, the Justice Department modified its Corporate Enforcement Policies, tightening the...