Fewer Individual Charges and More Focus on Third Parties in 2023’s FCPA Enforcements

Individuals being charged in FCPA enforcements have declined in recent years, even as the numbers of corporate enforcements have climbed, but this may change with the recent passage of the Foreign Extortion Prevention Act. Meanwhile, FCPA cases are increasingly focused on third-party intermediaries, Morrison Foerster’s 2023 FCPA Year in Review found. Another recent report, the Year in Review 2023 published by the Fraud Section of the DOJ’s Criminal Division, offered key details on FCPA matters. This article discusses significant trends and findings from both reports, including helpful data on what cooperative or remedial behaviors most often win companies credit when it comes to penalties. See “FCPA Enforcement, Changes in 2023 Foretell a Busy Year Ahead” (Jan. 17, 2024).

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