This past year saw a significant dip in the number of Foreign Corrupt Practices Act (FCPA) enforcement actions, but at the same time a series of new and important policy initiatives emanating from the White House and from the Department of Justice (DOJ) that signal a substantial commitment to investigating and prosecuting corruption-related crimes and to holding both individual and corporate actors accountable for such crimes. The FCPA enforcement docket for 2021 also reflects continuing efforts, and successes, by US enforcement authorities in achieving coordinated, multi-national investigations and resolutions, as well as a continued emphasis by DOJ on prosecuting individuals. On the international side, there were multiple noteworthy developments, in the OECD, in the World Bank and with other international financial institutions, and in key regions and jurisdictions around the world.
In this year’s Year in Review, we examine:
- Enforcement Statistics and Treads
- Government Enforcement and Compliance Guidance
- OECD Guidance
- Significant Legal Developments, Both Legislative and Judicial
- World Bank and Other International Financial Institutions
- International Developments
- 2021 FCPA Corporate Settlements
- 2021 Individual Enforcement Actions
Click here to read the full 2021 Year in Review. For more information on how these developments impact your organization, contact a member of Steptoe’s FCPA/Anti-Corruption team.