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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 2021.

DOJ Enforcement (Corporate)

The DOJ brought one corporate FCPA enforcement action in the first quarter. DOJ recovery in this action was $79.6 million.

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Where’s All the Action?

shrug

Today’s post is from Cuneyt Akay (Greenberg Traurig).

2021 is off to a slow start…at least in terms of FCPA corporate enforcement.  The DOJ has only announced one corporate settlement so far in 2021, and the SEC has had no corporate enforcement cases.

Many prognosticators were predicting big things for FCPA enforcement in 2021.  A perfect storm was brewing for 2021 FCPA enforcement.  Corporate enforcement set a record in 2019, which was then eclipsed in 2020.  Financial and economic crises, such as the current conditions caused by the COVID-19 pandemic, tend to increase corruption.  In addition, due to government investigations and proceedings being slowed down and paused for a good portion of 2020, the general consensus was that some enforcement actions would carry over into 2021.  On top of that, many anticipated a new administration would even be more active in pursuing enforcement of financial crimes and corporate fraud prosecutions.

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