Publicly announced Foreign Corrupt Practices Act (FCPA) enforcement activity in 2023 did not return to the levels seen a few years ago, as indicated by both the total number of cases against corporate and individual defendants and the combined total of monetary penalties. Nonetheless, senior officials at the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) again signaled that anti-corruption enforcement is a priority and that there will be significant and growing enforcement efforts going forward.
Contents includes:
I. 2023 Enforcement Trends and Key Developments
II. Key Policy Announcements
III. Key Investigation Related Developments
IV. Key Legal Developments
V. Collateral Actions
VI. Key International Legal Developments
VII. Conclusion
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