Enforcement of the US Foreign Corrupt Practices Act (FCPA) has
been down but not out this year in a world beset by the COVID-19
pandemic. While the pace of prosecutions against individuals seems
to have slowed in recent months, both the Department of Justice
(DOJ) and Securities and Exchange Commission (SEC) have continued
bringing significant enforcement actions against companies for
violating the FCPA. This enforcement activity reflects a persistent
focus on corruption in high-risk industries including healthcare,
defense contracting, energy, and financial services.
Meanwhile, the DOJ Criminal Division and SEC Enforcement
Division just this week released the Second Edition of their
"Resource Guide to the U.S. Foreign Corrupt Practices
Act," which was originally published in 2012. And last month
the DOJ Criminal Division updated its guidance on "Evaluation
of Corporate Compliance Programs."
