FCPA Resolutions Continuing at 'Slow' Pace, Law Firm Says
Resolutions involving the Foreign Corrupt Practices Act have continued at a “slow” pace in 2022, with only one announced FCPA-related corporate enforcement action during the first quarter of 2022, Miller & Chevalier said in its FCPA Spring Review released May 25. DOJ announced just two bribery-related guilty pleas in the first quarter and two FCPA-related indictments, the firm said. “This pace is consistent with the slower pace of such cases in 2021 and is well behind the pace that marked recent higher volume years such as from 2017 to 2019.”
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The “range of cases” during the first quarter, however, illustrates that DOJ is “continuing to use all the legal tools at its disposal to bring criminal charges against different types of corrupt actors, from company executives to foreign officials who allegedly received bribes,” the firm said. The review includes a description of recent FCPA-related regulatory and policy actions, a description of court cases of potential interest and an overview of the administration's FCPA-related actions so far, including “key takeaways” from each case.