Enforcement of the FCPA remained aggressive in the third year of the Trump Administration. In 2019, the SEC and DOJ imposed a record setting $2.9 billion in penalties. Although recent settlements largely appear to have been initiated under the Obama Administration, the Trump Administration has maintained Obama-era anti-corruption initiatives and policies. In a guest article, Dechert attorneys Jeremy B. Zucker, Darshak S. Dholakia and Hrishikesh N. Hari, and law clerk Tanya K. Warnke analyze 2019’s enforcement actions and SEC, DOJ and CFTC policy developments and enforcement trends. See “DOJ Enforcers Tout Transparency, the Defense Bar Responds” (Dec. 11, 2019).