Reading the Regulators: Shifts in FCPA Enforcement

This year has seen shifts in several key areas of anti-corruption expectations, and its second half might see a solidification of what is changing as cases proceed. Exactly what FCPA regulators expect from companies, for example in terms of voluntarily disclosing possible violations and cooperating with investigations, might become clearer in the coming months. So might regulators’ expectations of incentive clawbacks and off-channel message retention. In enforcement methodology, the use of data analytics is expected to become more prevalent. We distill insights offered by Davis Polk attorneys during a firm webinar regarding what to expect in FCPA enforcement in the remainder of this year. See “FCPA Corporate Enforcement Actions More Than Triple in 2022” (May 10, 2023). 

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