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2018 Year in Review: Top Anti-Corruption Enforcement Trends and Developments Bilingual

Q1 2019, Covington Alert

It was business as usual for FCPA enforcement in 2018. The U.S. Department of Justice (“DOJ”) and the U.S. Securities and Exchange Commission (“SEC”) collected a total of $1 billion from seventeen corporate defendants, including through their share of two high-value, multi-jurisdictional enforcement actions. DOJ also announced thirteen new FCPA prosecutions against individuals and used the money laundering and wire fraud statutes to pursue cases against foreign officials and others implicated in cross-border corruption schemes. The SEC, for its part, commenced FCPA enforcement actions against three individuals. Though the year did not see a meaningful change in the level of enforcement activity, DOJ announced several refinements to its FCPA enforcement policies, which seem unlikely to result in a substantial shift in practice, but helped to clarify the Department’s position on various issues. As for the SEC, the agency continued to aggressively pursue actions under the books and records and internal accounting controls provisions, including against foreign state-owned companies that were themselves the victims of corruption schemes.


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