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ARTICLE · 30 MAY 2023

International Trade, Enforcement & Compliance Recent Developments Update (May 24, 2023)

FCPA enforcement rebounded significantly in 2022, with significant increases in the number of corporate resolutions, total penalty amounts, and investigations under review.

United StatesInternational Law

Welcome to Foley's International Trade, Enforcement & Compliance Recent Developments Update

Recent developments include significant antitrust penalties, the issuance of CBP compliance guidance regarding the Uyghur Forced Labor Prevention Act, increasing emphasis on economic sanctions, "the new FCPA," and the creation of an interagency Disruptive Technology Strike Force. The Strike Force already has announced five indictments, underscoring the risks of non-compliance with export controls and economic sanctions requirements.

FCPA Enforcement Up Significantly

FCPA enforcement rebounded significantly in 2022, with significant increases in the number of corporate resolutions, total penalty amounts, and investigations under review. With this post-pandemic return to aggressive enforcement, has your organization reevaluated your anti-bribery and anti-corruption compliance programs or performed any audits regarding the proper operation of its internal controls?

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