FCPA: 2019 Year-In-Review

As we look back on 2019, several FCPA enforcement trends emerge. The following summarizes the key statistics and developments in 2019:

These statistics signal that in 2020, the government will continue to pursue enforcement actions aggressively, and the amount of overall sanctions will continue to grow. The number of declinations by the DOJ may continue to grow as the DOJ clarifies its corporate enforcement policy. We will continue to monitor these trends throughout 2020.

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