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ARTICLE · 23 JANUARY 2023

Global Anti-Corruption Insights: Winter 2023

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The US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) closed out 2022 by announcing two major corporate settlements under the Foreign Corrupt Practices Act...

GlobalCriminal Law
Soo-Mi Rhee
Soo-Mi Rhee
Marcus Asner
Marcus Asner
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Amy Jeffress
Kathleen Harris
Kathleen Harris
John N. Nassikas
John N. Nassikas
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Daniel Bernstein
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Ryan D. White
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The US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) closed out 2022 by announcing two major corporate settlements under the Foreign Corrupt Practices Act (FCPA): one for a total of $160 million (coordinated with Brazil) and another for a total of $460 million (coordinated with South Africa). The December announcements capped off a year in which DOJ and SEC disclosed a total of eight FCPA corporate enforcement actions. These include a $1.1 billion global agreement that the commodity trading and mining firm Glencore reached with authorities in the United States, United Kingdom, and Brazil-an agreement that required guilty pleas in New York and a compliance monitor for three years. Both the number and total dollar amount of corporate FCPA settlements were higher in 2022 than in 2021, though remained lower than in 2019 or 2020.

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