A new sheriff is in town, at least when it comes to combatting corruption, according to an analysis by international law firm Hughes Hubbard & Reed. In the New York-based law firm’s annual alert devoted to the state of Foreign Corrupt Practices Act (FCPA) violations and anti-bribery investigations, its chief contributors expect enforcement to surge in 2022.
The 153-page alert details key cases and investigations around the world from 2020 and 2021 to underpin predictions about what regulated companies can expect in the U.S. and beyond as the scope of the Biden administration’s enforcement philosophy comes into focus.
Here are a few of the key findings:
- The Department of Justice and Securities and Exchange Commission will be cooperating domestic agencies and divisions, as well as a growing number of non-U.S. enforcement agencies, to conduct complex bribery investigations.
- Companies that have resolved FCPA matters through non-prosecution agreements (NPAs), deferred prosecution agreements (DPAs) or plea agreements should expect increased scrutiny and attention to compliance with ongoing obligations under those agreements.
- While commodities traders expect greater scrutiny, enforcement will continue in a diverse array of traditional and non-traditional industries and in high-risk jurisdictions, with special emphasis on the independence and authority of corporate compliance functions and complete and timely cooperation with enforcement agencies.
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