FCPA/Anti-Corruption Developments: 2022 Year In Review

This past year saw an overall uptick of Foreign Corrupt Practices Act (FCPA) enforcement actions against both companies and individuals in 2022 as compared with the prior year, although numbers were still far below their peak of a few years ago. Coordinated, multijurisdictional investigations and resolutions, however, have become an established feature of the FCPA docket, and the Department of Justice points to that as an important success for enforcement. The Department also continued to stress the importance that it places on individual prosecutions and, indeed, in 2022 brought more FCPA cases against individuals than in the prior year; pursued other foreign bribery-related prosecutions against a number of individuals under anti-money laundering laws; and re-emphasized in the Department's written enforcement policy that a company that hopes to receive cooperation credit must, among other things, provide fulsome information to the Department that would assist it in