Enforcement of the US Foreign Corrupt Practices Act has been down but not out this year in a world beset by the COVID-19 pandemic. While the pace of prosecutions against individuals seems to have slowed in recent months, both the Department of Justice and Securities and Exchange Commission have continued bringing significant enforcement actions against companies for violating the FCPA. This enforcement activity reflects a persistent focus on corruption in high-risk industries including healthcare, defense contracting, energy, and financial services.
