This past year marked the 40th anniversary of the U.S. Foreign Corrupt Practices Act ("FCPA"). Since its enactment in 1977, the U.S. Department of Justice (the "DOJ") has brought approximately 300 FCPA enforcement actions, while the U.S. Securities and Exchange Commission (the "SEC") has brought approximately 200 cases.1 This anniversary year, the first year of the Trump administration, demonstrated that the FCPA continues to be a powerful tool in combating corruption abroad and encouraging compliance at global companies.
Below are six key take-aways regarding FCPA enforcement in 2017:
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Footnote
1. Richard L. Cassin, Someone had to be the first FCPA defendant, THE FCPA BLOG (Dec. 19, 2017), http://www.fcpablog.com/blog/2017/12/19/someone-had-to-be-the-first-fcpa-defendant.html.
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