Under the second year of the Trump Administration, the biggest
story was the increase of corporate declinations one year after the
DOJ adopted a permanent FCPA policy incentivizing self-disclosure,
cooperation, and remediation with the possibility of a
declination.
Corporate FCPA enforcement normalized in the second year of the
Trump Administration, after a low number of corporate resolutions
in 2017. In 2018, the DOJ and SEC resolved 16 corporate FCPA
cases—highlighted by three significant multijurisdictional
anticorruption resolutions—and collected $1 billion in fines
and penalties, and they continued their focus on individual
enforcement actions. These trends are an indication that the DOJ
and SEC continue to devote significant resources to FCPA corporate
enforcement, and the continued enhanced collaboration between U.S.
and foreign enforcement authorities demonstrates increasing
international cooperation and coordination.
