Over the course of the year — and even dating back to his time on the campaign trail — President Biden and senior officials in his administration, including Department of Justice and Security and Exchange Commission leadership, have emphasized the importance of anti-corruption enforcement. Yet in 2021, court filings, new investigation disclosures and penalty totals related to enforcement of the Foreign Corrupt Practices Act have each dropped to levels lower than what practitioners had become accustomed to in recent years.
The Biden administration has sent signals throughout the year indicating that it is primed to reverse this trend. Compliance teams should be prepared for a surge of activity in 2022.
Source:
- Kramer Levin: FCPA Enforcement Appears Primed to Reemerge
