FCPA/Anti-Corruption Developments: 2021 Year in Review
This past year saw a significant dip in the number of FCPA enforcement actions, but at the same time a series of new and important policy initiatives emanating from the White House and from the DOJ that signal a substantial commitment to investigating and prosecuting corruption-related crimes and to holding both individual and corporate actors accountable for such crimes.
The FCPA enforcement docket for 2021 also reflects continuing efforts, and successes, by US enforcement authorities in achieving coordinated, multi-national investigations and resolutions, as well as a continued emphasis by DOJ on prosecuting individuals. On the international side, there were multiple noteworthy developments, in the OECD, in the World Bank and with other international financial institutions, and in key regions and jurisdictions around the world.
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