As companies expand across borders and invest more heavily abroad, foreign enforcement authorities are following the example set by the U.S. Department of Justice and the U.S. Securities and Exchange Commission in directing resources toward aggressive enforcement of their respective countries’ laws against bribes paid to government officials. Today, international companies must consider not only the anti-corruption regulatory regimes in their home jurisdictions, but also the criminalization and prosecution of bribery in other locales — sometimes very distant ones — where they do business.

Although corporate compliance and enforcement priorities could shift under the new administration, the U.S. government is unlikely to significantly curtail anti-corruption enforcement, especially following the record-breaking penalties imposed in 2016. Indeed, as foreign agencies begin to more actively share the resource burden of global investigations, U.S. enforcement dollars could reach even further. This point is underscored by the recent uptick in coordinated, multijurisdictional investigations into corruption issues, including a spate of high-profile investigations involving authorities in the U.S. and Brazil. Most notably, Brazilian firms Odebrecht SA and Braskem SA paid a record-setting penalty of over $3.5 billion to resolve a bribery case involving American, Brazilian and other authorities. The stakes have never been higher.