Anti-Corruption Quarterly

2020 marked another significant year for Foreign Corrupt Practices Act (FCPA) enforcement. Despite COVID-19 restrictions, U.S. prosecutors at the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) continued to open new investigations, advance ongoing investigations, and reach resolutions totaling more than $3.7 billion in related corporate penalties, which excludes billions paid to foreign authorities in global resolutions. This year-end figure was the highest annual amount of penalties since the enactment of the FCPA. Two resolutions — one involving global aircraft provider Airbus SE (Airbus) and one involving global financial institution Goldman Sachs Group, Inc. (Goldman Sachs) — contributed significantly to that total. They were the two largest global anti-corruption resolutions of all time, amounting to more than $2 billion and $3 billion respectively in cumulative fines paid to