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ARTICLE · 02 AUGUST 2017

Global Anti-Corruption Insights: Summer 2017

Arnold & Porter
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Following a flurry of corporate settlements in the final days of the Obama Administration, enforcement of the US Foreign Corrupt Practices Act (FCPA) has been relatively quiet.

United StatesCriminal Law
Marcus Asner
Marcus Asner
Drew Harker
Drew Harker
Daniel Bernstein
Daniel Bernstein
Andrew Bauer
Andrew Bauer
Arthur Luk
Arthur Luk
Soo-Mi Rhee
Soo-Mi Rhee
Aaron Miner
Aaron Miner
Zheng He
Zheng He
Charles A. Kreafle
Charles A. Kreafle
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Following a flurry of corporate settlements in the final days of the Obama Administration, enforcement of the US Foreign Corrupt Practices Act (FCPA) has been relatively quiet. In the first six months of the Trump Administration, neither the US Department of Justice (DOJ) nor the US Securities and Exchange Commission (SEC) announced new charges against any company or entered into any deferred-prosecution or non-prosecution agreements with respect to FCPA violations. We suspected that the lull in enforcement actions would be short lived, however, as Trump Administration officials were quite open in expressing their commitment to vigorous enforcement of the FCPA. Our suspicions were confirmed in late July, when the SEC announced that it had resolved FCPA charges against Halliburton Company.

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