2021 Global Anti-Corruption Year in Review – Corporate/Commercial Law

United States: 2021 Global Anti-Corruption Year in Review

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In 2021, the number of publicly resolved cases under the Foreign Corrupt Practices Act (FCPA) was relatively low compared to previous years, but there were many interesting developments, and enforcement activity on the horizon. 2022 seems to be on the rise. It should be noted that the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced the lowest number of corporate resolutions in more than a decade. At the same time, in the first year of the Biden administration, law enforcement authorities have consistently maintained that the application remains active, and a number of policy and procedural announcements in DoJ and SEC quotes indicate that the volume of enforcement action is likely to increase in 2022. The new administration’s anti-corruption priorities and the release of several substantial policy initiatives towards the end of 2021 further suggest significant and growing enforcement efforts in the future.

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