December 6, 2021

Volume XI, Number 340

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December 03, 2021

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FCPA Year in Review 2020

2020 was another record-setting year in U.S. Foreign Corrupt Practices Act (FCPA) enforcement. In 2019, corporate FCPA enforcement set an all-time high with over $2.65 billion in fines and penalties. Additionally, that year, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) imposed the two largest FCPA corporate penalties, including the first billion-dollar settlement in FCPA history. In 2020, corporate FCPA enforcement eclipsed the 2019 record with $2.78 billion in total fines and penalties and set the record for the largest single FCPA penalty, which was a $1.6 billion settlement. 2020 also saw an increase in multi-jurisdictional cases, with foreign governments receiving over $5 billion in global anti-corruption settlements related to FCPA cases.

In addition, the government charged 36 individuals for FCPA and FCPA-related conduct, representing one of the highest numbers of individual prosecutions ever pursued in a year. The last three years have seen record individual enforcement related to FCPA matters. This development matches DOJ’s rhetoric that it will continue to strongly pursue individual prosecutions. 

Following is a snapshot of 2020 FCPA enforcement:

©2021 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume XI, Number 74
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About this Author

Cuneyt A. Akay Anti-Corruption Attorney Greenberg Traurig Denver, CO
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Cuneyt A. Akay is an anti-corruption lawyer focused on helping clients comply with the Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act. Cuneyt designs, builds, and implements effective compliance programs for clients around the world. Cuneyt’s experience includes conducting internal investigations, performing compliance risk assessments, handling pre-and post-acquisition compliance due diligence, training staff and third parties on compliance requirements, and assisting in the monitoring and auditing of anti-corruption programs.

Cuneyt also represents clients in complex...

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