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FCPA 2019 Year in Review

January 29, 2020 White Paper

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. 

Insights by Jones Day should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information purposes only and may not be quoted or referred to in any other publication or proceeding without the prior written consent of the Firm, to be given or withheld at our discretion. To request permission to reprint or reuse any of our Insights, please use our “Contact Us” form, which can be found on our website at www.jonesday.com. This Insight is not intended to create, and neither publication nor receipt of it constitutes, an attorney-client relationship. The views set forth herein are the personal views of the authors and do not necessarily reflect those of the Firm.
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