FCPA enforcements fell in 2021 to their lowest in a decade, but many signs point to a rebound in FCPA and anti-corruption prosecutions in the coming year. Attorneys with the international law firm Paul, Weiss, Rifkind, Wharton & Garrison summarize findings regarding corporate enforcement in 2021, compare it to previous years and look ahead at what’s to come in their 2021 FCPA year in review.
Here are a few of their notable findings:
- There were six total corporate enforcement actions in 2021, compared to 16 in 2020.
- Fines and penalties also dropped precipitously in 2021 — just $427 million compared to the high-water mark of 2020, when fines and penalties surpassed $6 billion.
- Every case the Department of Justice and Securities and Exchange Commission resolved in 2021 involved illegal conduct in more than one country, illustrating the growing complexity of FCPA and anti-corruption enforcement actions.
The Paul, Weiss report was authored by 21 of the firm’s attorneys with several associates contributing to the findings and analysis of FCPA enforcement actions.
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