FCPA Enforcement Outlook and Latest Compliance Guidance

Over the past year, the Foreign Corrupt Practices Act (FCPA) has remained an important fixture in the enforcement and compliance landscape for global companies. In 2023, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced 14 corporate resolutions, and, amid steady enforcement, DOJ and SEC also issued new and revised policies to encourage voluntary disclosure, increase individual accountability, and strengthen corporate compliance programs. At the same time, these efforts continued to fuel complementary enforcement and compliance efforts by regulators in other countries. Global companies know that it is critical to stay on top of these often complex and nuanced trends. In this article, we take stock of 2023 developments and trends underway in 2024.