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Monday, February 22, 2021 The year 2020 witnessed a record level of $2.78 billion in corporate fines and penalties from enforcement of the Foreign Corrupt Practices Act (FCPA) by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC). It also witnessed continued close cooperation by the DOJ and SEC with enforcement authorities in other countries, resulting in billions of additional dollars in fines and penalties by foreign enforcement authorities. These trends, which will likely continue and even expand in 2021, highlight the urgent need for companies to identify the key risk areas of FCPA exposure they face in their international operations, and to maintain compliance programs that work in practice, not just on paper. This is especially important for companies operating in or doing business with certain high-risk countries, such as China, India and Brazil, which may draw special attention from the DOJ and SEC because of recurring corrup

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