What to Expect When You’re Expecting (an FCPA Investigation): Federal Officials Look Ahead to 2022
The second day of the ABA’s 37th Annual White Collar Institute featured a panel with insights on the federal government’s Foreign Corrupt Practices Act priorities, most notably from panelists David Last and Charles Cain, heads of the DOJ’s and SEC’s respective FCPA Units. While both were proud of their teams’ work in Fiscal Year 2021, they each were looking forward to the year ahead, too. They said the public can expect to see the DOJ and SEC increase the number of significant resolutions of FCPA matters this year. Last pointed to two key reasons for this expected increase: (1) a tremendous upswing in international cooperation in recent years, and (2) a willingness to let the facts lead the prosecutors to any and all appropriate charges in any given case.
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