FCPA 2017 Year In Review

Under the Trump Administration, the number of DOJ and SEC corporate enforcement actions declined, with only five corporate FCPA resolutions in the last 49 weeks of the year. The number of 2017 Trump Administration corporate FCPA enforcement actions was a steep drop from the 25 corporate resolutions in 2016 and even lower than the number of corporate resolutions in the last three weeks of the Obama Administration.

However, the slowdown in corporate enforcement actions has not led to a slowdown in corruption investigations. The DOJ, FBI, and SEC continue to devote significant resources to FCPA investigations and prosecutions, and the enhanced collaboration between U.S. enforcement authorities and their foreign counterparts has increasingly led to heightened anticorruption enforcement activity in jurisdictions around the world.