The Pipe Is Always Full: FCPA Enforcement Officials Predict Business As Usual

Although the last 18 months of FCPA enforcement have involved more official policy “tweaks” than any other time since the U.S. began aggressively enforcing the statute, at the end of the day, not much has changed about the government’s actual positions or activities. This may be because “FCPA enforcement is maturing,” Gibson Dunn partner Richard Grime suggested at the Practising Law Institute’s recent Foreign Corrupt Practices Act and International Anti-Corruption Developments conference. Accordingly, only small policy changes are warranted. Speaking during the event, Daniel Kahn, Chief of the DOJ’s FCPA Unit, and Charles Cain, the head of the SEC’s FCPA Unit, seemed to confirm Grime’s hypothesis, sharing familiar explanations for the government’s policies on various matters, from self-reporting to prosecuting individuals. See “Quick Look at Recent DOJ Policy Changes” (Feb. 20, 2019).

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