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ARTICLE · 11 MARCH 2019

Foreign Corrupt Practices Act Enforcement In The Energy Sector

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The year 2018 marked a year of active Foreign Corrupt Practices Act ("FCPA") enforcement, with a significant focus on the energy sector.

United StatesCriminal Law

This is the sixth issue of WilmerHale's 10-in-10 Hot Topics in Energy Series. Over the course of 10 weeks, our attorneys will share insights on current and emerging issues affecting the US energy sector. Attorneys from across various practice groups at the firm will offer their take on issues ranging from congressional investigations, to the impact of key regulatory reforms, to emerging trends in domestic litigation and international arbitration. Read our other recent publications.


The year 2018 marked a year of active Foreign Corrupt Practices Act ("FCPA") enforcement, with a significant focus on the energy sector.1 Monetary penalties and individual prosecutions both rose in 2018, driven predominantly by the US government's focus on combatting corruption at some of Latin America's most prominent energy companies. The total monetary penalties imposed on corporations for FCPA-related conduct rose from $1.9 billion in 2017 to $2.9 billion in 2018, due in no

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