Recovering from a relatively slow start to the year, due in no small part to the global pandemic, the U.S. Foreign Corrupt Practices Act (“FCPA”) Units of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) closed the year with a bang. With 32 combined FCPA enforcement actions, 51 total cases including ancillary enforcement, and a record-setting $2.78 billion in corporate fines and penalties (plus billions more collected by foreign regulators), 2020 marks another robust year in the annals of FCPA enforcement.
This client update provides an overview of the FCPA and other domestic and international anti-corruption enforcement, litigation, and policy developments from 2020, as well as the trends we see from this activity. We at Gibson Dunn are privileged to help our clients navigate these challenges daily and are honored again to have been ranked Number 1 in the
By Jaclyn Jaeger2020-12-10T13:30:00+00:00
Major bribery scandals, record enforcement actions, unprecedented cross-border coordination and prosecutions all this amid a global pandemic made 2020 (for better or worse) an unforgettable year for the Foreign Corrupt Practices Act (FCPA). Expect more of the same in 2021.
“It’s a record year as far as our resolutions,” said Christopher Cestaro, chief of the FCPA Unit in the Department of Justice’s Fraud Section, speaking at an Oct. 29 anti-bribery virtual forum sponsored by TRACE International. Cestaro specifically cited settlements with Goldman Sachs and Airbus as “notable because of the magnitude of the bribery schemes and the record penalties.”