Recovering from a relatively slow start to the year, due in no small part to the global pandemic, the U.S. Foreign Corrupt Practices Act (“FCPA”) Units of the U.S. Department of Justice (“DOJ”) and Securities and Exchange Commission (“SEC”) closed the year with a bang. With 32 combined FCPA enforcement actions, 51 total cases including ancillary enforcement, and a record-setting $2.78 billion in corporate fines and penalties (plus billions more collected by foreign regulators), 2020 marks another robust year in the annals of FCPA enforcement.
This client update provides an overview of the FCPA and other domestic and international anti-corruption enforcement, litigation, and policy developments from 2020, as well as the trends we see from this activity. We at Gibson Dunn are privileged to help our clients navigate these challenges daily and are honored again to have been ranked Number 1 in the
In October, the World Bank Group (WBG) published its third
Sanctions System Annual Report for Fiscal Year 2020 (FY20), which covers the period from 1 July 2019 to 30 June 2020. The report provides a detailed look at the recent activities of the three units of the WBG s Sanctions System – the Integrity Vice Presidency (INT), the Office of Suspension and Debarment (OSD), and the Sanctions Board – and provides important insights into priorities for the coming year.
An overview of activities in FY20
The WBG s Sanctions System addresses allegations that firms and individuals involved in WBG-financed projects committed sanctionable practices. INT investigates these allegations in the first instance. If INT determines there is sufficient evidence to pursue sanctions, it may seek to negotiate a settlement with the accused or it may submit a Statement of Accusations and Evidence to OSD, the first tier of review in adjudicating whether to impose sanctions. OSD s sanctions decisions may
Introduction
In October 2020 the World Bank Group (WBG) published its third Sanctions System Annual Report FY20, which covers 1 July 2019 to 30 June 2020. The report provides a detailed look at the recent activities of the three units of the WBG s sanctions system:
the Integrity Vice Presidency (INT);
the Office of Suspension and Debarment (OSD); and
the Sanctions Board.
Overview of FY20 activities
The WBG s sanctions system addresses allegations that firms and individuals involved in WBG-financed projects committed sanctionable practices. INT investigates these allegations in the first instance. If INT determines that there is sufficient evidence to pursue sanctions, it may seek to negotiate a settlement with the accused or submit a statement of accusations and evidence to the OSD – the first tier of review in adjudicating whether to impose sanctions. The OSD s sanctions decisions may be appealed to the Sanctions Board – the second and final tier of review.