Despite the significant obstacles presented by COVID-19, the DOJ and the SEC assessed a record-breaking total in corporate FCPA penalties, and foreign authorities assessed a similar amount. The number of corporate FCPA enforcement actions resolved by the DOJ and the SEC remained comparable to prior years, while the number of individual prosecutions dropped considerably, perhaps due to challenges posed by the pandemic. The DOJ and the SEC also announced several policy revisions intended to increase transparency and consistency in FCPA enforcement. In this alert, we reflect on the year’s most significant anti-corruption and FCPA developments.
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