FCPA Enforcement And Anti-Corruption Developments: 2020 Year In Review

Executive Summary

Despite the significant obstacles presented by the global pandemic, U.S. enforcement agencies remained "open for business" in 2020, ¹ with the DOJ and the SEC assessing a record-breaking combined total of nearly $2.8 billion in corporate penalties in FCPA settlements, and foreign authorities assessing an additional $2.9 billion in penalties in related cases. The number of corporate FCPA enforcement actions resolved by the DOJ and the SEC remained comparable to prior years, and clearly signaled the U.S. authorities' enduring commitment to vigorous enforcement of the FCPA and to multilateral cooperation.

Although both the DOJ and the SEC continued to emphasize individual accountability, in a departure from recent years, both authorities announced considerably fewer individual prosecutions, returning to levels seen in 2015. The decline may reflect the impact of the pandemic on the authorities' ability to bring new criminal charges or initiate civil