Coming Year’s FCPA Enforcement Developments Build on Eventful 2023

Anti-corruption regulators are boosting international cooperation, intensifying the use of data analytics, and treating issuers and non-issuers more evenly. These are some stand-out enforcement trends highlighted from the government and advisory side at the turn of the year. Acting Assistant AG Nicole M. Argentieri said a new International Corporate Anti-Bribery initiative team will expand partnerships, and she emphasized fast and proactive self-disclosure and cooperation as factors leading to discounted penalties. The DOJ will step up its use of data analytics in FCPA matters and expects companies to do so too. Reviewing 2023’s developments and what to expect in 2024, this article distills insights from Hughes Hubbard & Reed, Miller & Chevalier, Davis Polk and Kona AI while summarizing Argentieri’s points. See “Assistant AG Polite Discusses Declinations in Cases With Aggravating Circumstances and Revised ECCP” (Apr. 12, 2023).

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