Latin America Anti-Bribery Year-in-Review: 2021 Developments and Predictions for 2022

Although the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases in 2021 was relatively low compared to prior years, enforcement actions related to Latin America played a particularly prominent role. Many of the cases investigated and resolved by US regulators involved Latin American citizens, companies operating in Latin America, and high-profile corruption scandals arising in Latin American countries.

Continuing international cooperation between enforcement authorities made cross-border coordination on both investigations and resolutions a hallmark of anti-corruption enforcement this year, as highlighted by close work between US and Brazilian authorities. At the same time, many Latin American authorities have expanded their own anti-corruption enforcement efforts. This interconnected and energetic global enforcement environment signals sustained and aggressive forthcoming anti-corruption efforts.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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