INTRODUCTION
U.S. Foreign Corrupt Practices Act (FCPA)-related public
enforcement activity through the second quarter of 2021 continued
to be steady and relatively slow, likely due in part to the
lingering effects of the COVID-19 pandemic. The U.S. Department of
Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC)
each announced one corporate FCPA resolution, with U.K.-based
construction engineering company Amec Foster Wheeler Energy
Limited. However, as courts in the United States gradually reopen,
the announcement of individual enforcement actions is catching up
with recent years, with one individual pleading guilty to FCPA
charges, one pleading guilty to conspiracy to commit money
laundering in a bribery scandal, and 12 more individuals receiving
sentencings in the past quarter. Additionally, the DOJ announced
new charges against two former Bolivian government officials and
three U.S. citizens and unsealed another indictment from 2019
against two
