In the third year of the Trump Administration, the biggest Foreign Corrupt Practices Act ("FCPA") headlines were record corporate fines and penalties, and a banner year of individual FCPA enforcement highlighted by three DOJ trial victories. The DOJ clarified aspects of its FCPA corporate enforcement policy and provided additional guidance regarding effective corporate ethics and compliance programs. Abroad, the DOJ and SEC continued to coordinate with foreign authorities, publicly acknowledging cooperation from 26 countries and territories.
This past year demonstrated that the DOJ's and SEC's FCPA corporate and individual enforcement is not waning and is instead reaching new heights, in close coordination with anticorruption authorities around the globe. This White Paper examines the key enforcement highlights of 2019.