2017 was a year of transition for US enforcement of the Foreign Corrupt Practices Act (FCPA) and saw a substantial increase in global anti-corruption enforcement. As we advised in our 2017 FCPA Mid-Year Review, last year started with a flurry of FCPA enforcement at the conclusion of the Obama Administration, followed by a prolonged lull as the Trump Administration reviewed enforcement policies and filled key positions at the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC). FCPA enforcement resumed in earnest in the third and fourth quarters of 2017, putting the year well within the usual range of reported corporate and individual prosecutions for the last five years. Those enforcement trends continued in the first quarter of 2018, with both the DOJ and SEC inking corporate resolutions.
For more information, please see our advisory.