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What You Need To Know From Q3

q3

This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the third quarter of 2021. (See here for Q1 and here for Q2).

DOJ Enforcement (Corporate)

The DOJ did not bring any corporate FCPA enforcement action in the third quarter.

DOJ Enforcement (Individual)

The DOJ announced three individual FCPA enforcement actions in the third quarter.

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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 2021. As highlighted below, in two core corporate enforcement actions, the DOJ/SEC have secured net $140.3 million in FCPA settlement amounts. None of the corporate enforcement actions have resulted in any related charges against company employees.

For a similar post at the mid-point of 2020 see here, for 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 2021.

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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 2021. (See here for Q1).

DOJ Enforcement (Corporate)

The DOJ brought one corporate FCPA enforcement action in the second quarter. DOJ recovery in this action was net $7.6 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 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?

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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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