As we look back on the anti-corruption enforcement trends we saw in 2023, there were several key developments.
The Department of Justice (“DOJ”) brought 11 enforcement actions in 2023. Only six were against companies -...more
In late January 2022, the Department of Justice (“DOJ”) issued Opinion Procedure Release 22-01, its first Foreign Corrupt Practices Act (“FCPA”) Opinion since 2020. The opinion states that based on the specific facts...more
As we look back on 2021, several anti-corruption enforcement trends emerge. The following summarizes the key developments of the prior year and trends to watch in 2022:
The Department of Justice (“DOJ”) brought 24...more
2/2/2022
/ Anti-Corruption ,
Biden Administration ,
Compliance ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Foreign Corrupt Practices Act (FCPA) ,
National Security ,
Sanctions ,
Securities and Exchange Commission (SEC) ,
Whistleblower Awards ,
Whistleblowers
In August 2021, the Securities and Exchange Commission (the “SEC”) announced multiple sizable whistleblower awards totaling approximately $16.1 million to 14 individuals. The awards ranged from $150,000 to $3.5 million. These...more
On April 29, 2021, the U.S. Department of Treasury’s Office of Foreign Assets Control (“OFAC”), the agency that enforces and administers U.S. economic and trade sanctions, announced a settlement with Dallas-based MoneyGram...more
As we look back on 2020, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2020:
•The Department of Justice (“DOJ”) brought 29 enforcement actions in 2020. 7 companies...more
In November 2019, the U.S. Department of Justice (“DOJ”) issued revisions to the Foreign Corrupt Practices Act (“FCPA”) Corporate Enforcement Policy (“Policy”). The Policy, which was first introduced in 2016, offers...more
As we look back on 2019, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2019:
The Department of Justice (“DOJ”) brought 29 enforcement actions in 2019. 12 guilty...more
With the first half of 2019 in the rearview mirror, it is a good opportunity to review the overall trends in Foreign Corrupt Practices Act (“FCPA”) enforcement actions brought by the Department of Justice (“DOJ”) and...more
On March 6,2019, at the ABA’s National Institute on White Collar Crime, Jamie McDonald, the Director of the Commodity Futures Trading Commission’s (“CFTC”) Division of Enforcement, announced the publication of a new...more
As we kick off a new year, businesses should take the time to review their anti-corruption and compliance programs and make sure they are up-to-date and adaptable to the continuously changing environment. Here are five...more