SEC and DOJ Officials Predict That Current FCPA Enforcement Trends Will Continue, Defense Attorneys Agree

FCPA enforcement, both in terms of the number of prosecutions and the priorities of the government, will hold steady in 2018, Charles Cain, head of the SEC’s FCPA Unit, and David Johnson, Assistant Chief of the DOJ’s FCPA Unit, indicated during a recent event sponsored by the Practising Law Institute. Noting that 2016 was a banner year for FCPA prosecutions, Cain observed that enforcement in 2017 was more in line with historical norms and predicted that the same would be true in 2018. Johnson and Cain also confirmed that, going forward, the government will remain committed both to prosecuting individuals and cooperating with foreign counterparts to enforce global anti-corruption laws. See “Any Decrease in FCPA Enforcement Under Trump Will Be Overshadowed by International Enforcement, Experts Predict” (Apr. 4, 2018).

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