Anti-Corruption Enforcement: 2022 Year-In-Review

The following summarizes our team’s monitoring of key developments in anti-corruption enforcement during 2022 and what that may mean going forward in this new year:

Throughout 2022, the DOJ and SEC continued to aggressively pursue enforcement actions and work with law enforcement agencies around the world to combat corruption. In fact, in January 2023, Assistant Attorney General Kenneth Polite publicly commented on the work of the DOJ’s Fraud Section, which investigates and prosecutes white collar crime, including the FCPA. He noted the numerous individual convictions, corporate criminal resolutions and corporate enforcement declinations secured by the Fraud Section in 2022, and he promised that there will be more enforcement actions in 2023. 

We will continue to monitor emerging anti-corruption trends throughout 2023. Our next post will focus on the DOJ’s recent changes to its Criminal Division Corporate Enforcement and Voluntary Self-Disclosure Policy and the potential impact going forward.

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