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In remarks at the American Conference Institute’s 37th International Conference on the Foreign Corrupt Practices Act (FCPA) on December 3, 2020, Gen. Brian C. Rabbit, then acting assistant attorney general of the U.S. Department of Justice (DOJ), stated that “[n]otably, many of [DOJ’s] corporate resolutions in 2020 included coordination with one or more foreign enforcement authorities an increasingly important aspect of [DOJ’s] work.”
His statement reflects a continuing trend over the last several years, in which DOJ and the Securities and Exchange Commission (SEC) have increasingly coordinated with foreign enforcement authorities to resolve multi-jurisdictional FCPA cases. Such increased coordination in multi-jurisdictional enforcement has coincided with or resulted from an increase in enforcement by foreign countries. Other countries may be recognizing more and more the financial gains of coordinated cross-b
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