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Contrary to some expectations, the Trump Administration Department of Justice imposed record penalties under the U.S. Foreign Corrupt Practices Act from 2017 through 2020. But in each of those years, fewer and fewer new FCPA investigations were initiated. We expect the Biden Administration to continue the trend of increasing FCPA enforcement settlement values, while also increasing the pace of initiating new FCPA investigations. Anticorruption matters present some of the most severe threats to a company’s organizational integrity. Understanding the changing enforcement culture is an important component to addressing those threats.
Continue Reading The Next Four Years of FCPA Enforcement: What to Expect From the Biden Administration

You may have heard of the Yates Memorandum, which sets forth current Justice Department policy on corporate cooperation with criminal investigations. But the Securities and Exchange Commission has just announced another significant policy change, which hasn’t garnered the same attention: self-disclose or forfeit access to key favorable case dispositions.
Continue Reading When Voluntary Self-Disclosure Isn’t so Voluntary: SEC Says Self-Disclose or Forfeit Non-Prosecution and Deferred Prosecution