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
HAPPY BIRTHDAY SAGITTARIUS
(November 22-December 21) I m envisioning a scene in which you re sitting on a chair at a kitchen table. At the centre of the table is a white vase holding 18 long-stemmed red roses. The rest of the table s surface is filled with piles of money, which you have just unloaded from five mysterious suitcases you found at your front door. All of that cash is yours, having been given to you no-strings-attached by an anonymous donor. You re in joyful shock as you contemplate the implications of this miraculous gift. Your imagination floods with fantasies about how different your life can become. Now, Sagittarius, I invite you to dream up at least three further wonderfully positive fantasies involving good financial luck. That s the medicine you need right now.