As 2020 drew to a close, enforcement authorities throughout the United States and the Americas continued to investigate fraud, corruption, and other misconduct across the region. In this newsletter, we highlight some developments from closing months of 2020.

The developments include, amongst others, Vitol Inc’s DOJ and parallel Brazilian resolution in respect of allegations of bribery in Brazil, Ecuador and Mexico, and J&F Investimentos SA’s US resolution in relation to allegations of bribery in Brazil. With these settlements, 2020 became DOJ’s largest year for FCPA recoveries, with resolutions totaling nearly $3 billion. The Vitol and J&F settlements also brought total FCPA penalties to over $20 billion since the inception of the FCPA in 1977.