In order to provide an overview for busy in-house counsel and
compliance professionals, we summarize below some of the most
important international anti-corruption developments from the past
month, with links to primary resources. This month we
ask: How did foreign bribery enforcement in the United States
in 2020 compare to global enforcement trends? What guidance
did the UK Serious Fraud Office (SFO) provide regarding deferred
prosecution agreements (DPAs)? What changes are being
contemplated for China's commercial bribery laws? The
answers to these questions and more are here in our October 2020
Top 10.
1. FCPA Settlement Amounts Break Record.
With three FCPA enforcement actions in October 2020 (see
here, here,
here, here,
and
here), this year became the largest ever for FCPA settlement
amounts, with resolutions totaling nearly $6 billion. The
aggregate amount recovered in 2020 to date more than doubles the
previous high of $2.9 billion set in 2019.
