2020 in Review: Big FCPA Numbers Despite a Pandemic

When the COVID-19 pandemic hit, many thought 2020 would be a wash, with the usually jet-setting FCPA bar, both defense and prosecution, stuck at home. However, with grace and patience on all sides, everyone has learned to make do. At the American Conference Institute’s Annual International Conference on the Foreign Corrupt Practices Act, enforcers reflected with pride on their accomplishments in this strange year. The Anti-Corruption Report attended the conference – virtually of course – and spoke with defense counsel to get their point of view. In this first article looking back at anti-corruption efforts in 2020, we examine the year in enforcement, including the pandemic effect, what the big settlement numbers mean for companies and what to expect from the new administration in January. Future articles will look at the “downtick” in monitorships, efforts to coordinate settlements and how compliance expectations have changed. See “New Head Says the Criminal Division Is Open for Business” (Jul. 22, 2020).

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