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ARTICLE · 10 AUGUST 2018

Global Anti-Corruption Insights: Summer 2018

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Enforcement of the US Foreign Corrupt Practices Act (FCPA) was much more active in the first half of this year than in the first half of 2017, the Trump Administration's first year in office.

GlobalCriminal Law
Marcus Asner
Marcus Asner
Warren J. Bernstein
Warren J. Bernstein
Lindsey D. Carson
Lindsey D. Carson
Andrew Bauer
Andrew Bauer
Soo-Mi Rhee
Soo-Mi Rhee
Samuel Witten
Samuel Witten
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Jamen Tyler
Amanda J. Raines
Amanda J. Raines
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Enforcement of the US Foreign Corrupt Practices Act (FCPA) was much more active in the first half of this year than in the first half of 2017, the Trump Administration's first year in office. So far this year, the US Department of Justice (DOJ) has resolved five FCPA enforcement actions against companies—including French bank Société Générale S.A., which agreed to pay $585 million in the first coordinated settlement of an international bribery case with French authorities. That settlement, the fifth-largest FCPA settlement of all time, followed the May 9, 2018, announcement by Deputy Attorney General Rod Rosenstein of a new policy promoting coordination within the DOJ and with other US and foreign enforcement agencies when imposing multiple penalties for the same conduct. The DOJ, moreover, recently has secured guilty pleas and jail sentences, as well as unsealed new criminal charges against individuals in a variety of FCPA cases.

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