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ARTICLE · 08 FEBRUARY 2017

Global Anti-Corruption Insights Winter 2017 - Update on Recent Enforcement, Litigation, and Compliance Developments

Arnold & Porter
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2016 also was notable for the level of international cooperation on anti-corruption matters.

GlobalCriminal Law
Marcus Asner
Marcus Asner
Drew Harker
Drew Harker
Daniel Bernstein
Daniel Bernstein
Lindsey D. Carson
Lindsey D. Carson
John Cella
John Cella
Elizabeth T.M. Fitzpatrick
Elizabeth T.M. Fitzpatrick
Matthew Lanahan
Matthew Lanahan
James McSweeney
James McSweeney
Whitney A. Moore
Whitney A. Moore
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2016 proved to be a record-setting year for US anti-corruption enforcement with the Department of Justice and Securities and Exchange Commission collecting a total of approximately US$2.5 billion in fines, disgorgement, and interest from 27 companies in connection with charges under the Foreign Corrupt Practices Act. Ten individuals pleaded guilty to criminal FCPA charges, while a number of others resolved civil FCPA charges with the SEC. The DOJ also issued five "declinations" under its new FCPA Pilot Program, which seeks to reward companies for their voluntary self-disclosure of potential violations, cooperation with authorities, and remediation of compliance program deficiencies.

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