Focus on the US
An active FCPA docket anticipated
When compared to prior years, 2015 was relatively quiet for
Foreign Corrupt Practices Act (FCPA) enforcement actions
in the US. Although the total number of enforcement actions was
slightly higher than the previous year, there was an absence of the
very large monetary settlements that garnered enormous attention in
the recent past. This record, combined with continued criticism
that their enforcement actions in the past failed to hold
individuals accountable for violations of federal law, including
the FCPA, may be the reasons for two significant changes in the
government's approach to enforcement. This raises the question
as to whether the coming year will be much less quiet than the
previous year.