Foreign Corrupt Practices Act ("FCPA") enforcement has yet to rebound from the immediate pre-pandemic period. In 2022, DOJ and SEC resolved eight corporate FCPA matters for $878 million, including four resolutions coordinated with foreign regulators. DOJ also announced seven indictments and pleas under the FCPA, and SEC announced no individual FCPA enforcement actions. The drop in FCPA enforcement statistics is likely temporary. The Biden administration continues to prioritize anticorruption enforcement, announcing several major changes to corporate criminal enforcement policies and corporate compliance programs, signaling a more aggressive posture toward corporate and individual FCPA enforcement.
This White Paper reviews 2022 FCPA enforcement and describes what lies ahead.
Attachments FCPA 2022 Year In Review.pdf
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