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ARTICLE · 09 MAY 2023

FCPA Enforcement: New Corporate Enforcement Policy, Aggressive Enforcement, And Lessons Learned From Recent Resolutions

Bass, Berry & Sims PLC
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Please join us for a lively and timely discussion of recent FCPA enforcement activity on Tuesday, May 23, 2023 at 1pm ET/12pm CT.

United StatesGovernment, Public Sector
Lindsey Brown Fetzer
Lindsey Brown Fetzer
Thaddeus R. McBride
Thaddeus R. McBride

Please join us for a lively and timely discussion of recent FCPA enforcement activity on Tuesday, May 23, 2023 at 1pm ET/12pm CT.

Battling bribery and corruption remains a core priority of the Biden Administration, with the DOJ and SEC aggressively enforcing the FCPA. In 2022, the DOJ and SEC assessed nearly $1.4 billion in penalties and fines, a significant increase over 2021. In addition, in early 2023, the DOJ announced significant new expectations in the context of corporate enforcements and voluntary disclosures.

FCPA settlements reached in the past year provide important lessons for companies and their counsel. Among recent enforcement actions are the DOJ's prosecution of Glencore, which resulted in a $700 million fine for FCPA violations, a guilty plea, and appointment of a three-year compliance monitor, and the $460 million settlement with three-time offender ABB Ltd. There are important lessons from several other settlements as well.

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