Tuesday, January 5, 2021
Over the last two decades, U.S. Foreign Corruption Practices Act (FCPA) enforcement has steadily increased regardless of the political climate or administration in power. FCPA penalties and settlements hit record highs during the last four years, with 2020 and 2019 being the two largest years ever for FCPA enforcement in terms of total penalty amounts. The two previous years were also in the top ten.
We anticipate that the incoming Biden administration will actively pursue enforcement of financial crimes, corporate fraud prosecutions, and increased regulatory oversight. Financial and economic crises, such as the current conditions caused by the COVID-19 pandemic, generally increase corruption. Given the new administration and economic backdrop, we expect a continued increase in FCPA enforcement in the coming years.