The second year of the COVID pandemic offered a sense of recovery for much of the world’s economy, but it also marked a jump in reports of corruption as well as legislation to combat wrongdoing, according to legal experts at Gibson Dunn’s 12th annual FCPA webcast on trends in emerging markets. Moderator Joseph Warin was joined by attorneys Kelly Austin, Patrick Stokes, Joel Cohen, Benno Schwarz and Karthik Thiagarajan.
In this first installment of our coverage of the program, we discuss U.S. enforcement, global FCPA trends and the compliance and enforcement landscape in China. In the second installment, we will cover anti-corruption efforts in Latin America, India, Africa and Russia.
See “Evolving Global Anti-Corruption Efforts: U.S., China and India” (Feb. 17, 2021).
Nuanced FCPA Enforcement in the U.S.
Though he never imagined the series surpassing several U.S. presidents, Warin said that President Biden’s first year continues a pattern of “new nuanced approaches to enforcement activity.”
Last year marked a notable drop in both DOJ and SEC FCPA actions – a total of 11 by DOJ and four by the SEC – continuing a drop since a record number of combined actions in 2019. Stokes, former head of the DOJ’s FCPA unit, cautioned that this is less a reflection of political whim and more a reality of staffing changes and the complexity of transferring ongoing investigations to new leadership.
The second year of the COVID pandemic offered a sense of recovery for much of the world’s economy, but it also marked a jump in reports of corruption as well as legislation to combat wrongdoing, according to legal experts at Gibson Dunn’s 12th annual FCPA webcast on trends in emerging markets. Moderator Joseph Warin was joined by attorneys Kelly Austin, Patrick Stokes, Joel Cohen, Benno Schwarz and Karthik Thiagarajan.
In this first installment of our coverage of the program, we discuss U.S. enforcement, global FCPA trends and the compliance and enforcement landscape in China. In the second installment, we will cover anti-corruption efforts in Latin America, India, Africa and Russia.
See “Evolving Global Anti-Corruption Efforts: U.S., China and India” (Feb. 17, 2021).
Nuanced FCPA Enforcement in the U.S.
Though he never imagined the series surpassing several U.S. presidents, Warin said that President Biden’s first year continues a pattern of “new nuanced approaches to enforcement activity.”
Last year marked a notable drop in both DOJ and SEC FCPA actions – a total of 11 by DOJ and four by the SEC – continuing a drop since a record number of combined actions in 2019. Stokes, former head of the DOJ’s FCPA unit, cautioned that this is less a reflection of political whim and more a reality of staffing changes and the complexity of transferring ongoing investigations to new leadership.
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