2020 in Review: More Coordination, Fewer Monitors

The year 2020 was a strange one in many ways but, as discussed in our first article looking back at the year, anti-corruption enforcement continued, albeit with some adjustments. The two most notable trends of the year were U.S. enforcers’ continued efforts to coordinate settlements, both domestically and with foreign enforcement authorities, and a marked decrease in the number of settlements requiring independent compliance monitors. The Anti-Corruption Report attended the American Conference Institute’s Annual International Conference on the Foreign Corrupt Practices Act held in December - where enforcers from the DOJ, SEC and beyond discussed these trends - and reached out to members of the defense bar to discuss the implications. See “Significant Remediation Spares Goldman Sachs a Monitor in Biggest FCPA Settlement in History” (Nov. 11, 2020).

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