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Mid-Year FCPA Report

mid-year report

This post highlights Foreign Corrupt Practices Act enforcement and related developments at the mid-point of 2020. As highlighted below, in four core corporate enforcement actions, the government has secured $674 million. None of the enforcement actions have resulted in any related charges against company employees.

For a similar post at the mid-point of 2019 see here, for 2018 see here, for 2017 see here, and for 2016 see here.

This post breaks down FCPA enforcement into the following categories: DOJ (corporate); DOJ (individual); SEC (corporate); and SEC (individual). Thereafter, this post highlights other FCPA developments or items of interest thus far in 2020.

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What You Need To Know From Q2

Q2

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the second quarter of 2020. For a similar post from Q1 2020, see here.

In many respects, the second quarter of 2020 was likely the most unique quarter in FCPA history given the impacts of COVID-19.

DOJ Enforcement (Corporate)

The DOJ brought one corporate FCPA enforcement action in the second quarter. DOJ recovery in this action was approximately $234 million.

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What You Need To Know From Q1

Q1

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2020. In many respects, the first quarter (and foreseeable future) is divided into a pre-COVID-19 environment and post-COVID-19 environment (circa March 10th).

DOJ Enforcement (Corporate)

The DOJ brought one corporate FCPA enforcement action in the first quarter. DOJ actual recovery in this action was $294 million.

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