2022: The FCPA Year in Review
The Justice Department and the Securities and Exchange Commission bounced back in 2022 to restore their records for aggressive FCPA enforcement. At the same time, DOJ announced significant new compliance program expectations, and appeared ready to press forward with a number of FCPA resolutions. The Numbers For the year, DOJ totaled five corporate resolutions, two separate declinations under its Corporate Enforcement Policy, and approximately 24...