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ARTICLE · 23 JANUARY 2024

Global Anti-Corruption Insights: Winter 2024

Arnold & Porter
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Reports of the Foreign Corrupt Practices Act's demise remain greatly exaggerated.

GlobalCriminal Law
Marcus Asner
Marcus Asner
Kathleen Harris
Kathleen Harris
Amy Jeffress
Amy Jeffress
John N. Nassikas
John N. Nassikas
Soo-Mi Rhee
Soo-Mi Rhee
Daniel Bernstein
Daniel Bernstein
Junghyun Baek
Junghyun Baek
Eliza Buergenthal
Eliza Buergenthal
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Reports of the Foreign Corrupt Practices Act's demise remain greatly exaggerated. The U.S. Department of Justice and U.S. Securities and Exchange Commission kicked off the new year by announcing, on January 10, a US$220 million settlement with a German company that paid bribes in South Africa and Indonesia to win government contracts.

In 2023, U.S. authorities overall brought roughly the same number of corporate FCPA cases as in 2022. DOJ settled criminal FCPA charges with five companies, while the SEC settled civil FCPA charges with nine (two in parallel with DOJ). The total dollar amount collected from FCPA cases was lower in 2023, however, with the largest settlement being the US$218 million paid by a publicly traded chemicals manufacturer based in the United States. DOJ also issued two official declinations pursuant to its Corporate Enforcement Policy.

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