Tagged: FCPA enforcement trends

Episode 176 — 2020 FCPA Enforcement and Compliance Trends

The Justice Department and the Securities and Exchange Commission had another record year of enforcement.  In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020.  After those two years, 2016, 2014, 2010 were larger enforcement years (as measured by total fines) than 2017 and 2018, the first two years of FCPA enforcement under the Trump Administration. In this...

2020 FCPA Review: Another Record Year for Enforcement (Part I of IV)

The Justice Department and the Securities and Exchange Commission had another record year of enforcement.  In fact, the last four years of FCPA enforcement included two years of record enforcement – 2019 and 2020.  After those two years, 2016, 2014, 2010 were larger enforcement years (as measured by total fines) than 2017 and 2018, the first two years of FCPA enforcement under the Trump Administration....

Four Current FCPA Enforcement Trends

There are two distinct themes in FCPA enforcement – the first is consistency, i.e., that some enforcement actions are relatively consistent across the board and, in the last five to ten years, the FCPA caseload has been fairly steady; the second is variability, meaning that new policies have an impact on FCPA enforcement.  Some minor and some major.  All of this may be another in...

Trends from 2016 Record FCPA Enforcement Year (Part II of III)

No matter how you cut it – this was a big year in FCPA enforcement. Not just because of the large enforcement actions but the scope and depth of enforcement, remediation and compliance program demands. We are witnessing a significant turning point in FCPA enforcement in which the Justice Department and the SEC are slowly but surely pushing companies to embrace a more robust ethics...