In the spring of 2020, while the COVID-19 pandemic was racing through the United States and keeping many at home, enforcers at the DOJ and SEC spent some of the downtime updating their compliance guidance. These changes, along with public statements by enforcers and the terms of negotiated settlement deals, continued to highlight that enforcers believe corporate compliance programs play an important role in preventing corruption. In December, the Anti-Corruption Report attended the American Conference Institute’s Annual International Conference on the Foreign Corrupt Practices Act, where enforcers discussed their compliance expectations. We followed up with members of the defense bar for their perspectives on the year in compliance. See the first two parts of our 2020 in Review series: “Big FCPA Numbers Despite a Pandemic
” (Dec. 16, 2020) and “More Coordination, Fewer Monitors
” (Jan. 6, 2020).