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2020 Year in Review: Top Anti-Corruption Enforcement and Compliance Trends and Developments

January 20, 2021, Covington Alert

Based on the top-line numbers, 2020 was a banner year for U.S. Foreign Corrupt Practices Act (“FCPA”) enforcement. We saw several record-setting fines as U.S.-recovered penalties from corporate resolutions totaled more than $2.75 billion—the highest on record; and a new company entered the all-time U.S. recoveries Top 10 resolutions list. While some commentators have questioned whether one metric or another signals a less robust anti-corruption enforcement environment, public data from the past dozen or more years shows that FCPA enforcement has remained robust for a sustained period. We expect that the incoming Biden administration will place an even higher priority on anti-corruption enforcement. Put simply, we expect that FCPA enforcement will remain a mainstay of the U.S. Department of Justice’s (“DOJ” or the “Department”) and the U.S. Securities and Exchange Commission’s (the “SEC”) enforcement programs, and companies should assume that anti-corruption enforcement will only increase in the years ahead.

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