Is FCPA Individual Enforcement at Odds With Government Rhetoric?

June 8, 2023  |  New York Law Journal

Recent pronouncements from both DOJ and SEC officials, the two agencies responsible for enforcement of the Foreign Corrupt Practices Act, emphasize the importance of holding individuals accountable for foreign bribery. These announcements, however, are at odds with the recent steady decline in the volume of actual enforcement activity. In their latest article for the New York Law Journal, "Is FCPA Individual Enforcement at Odds with Government Rhetoric?" Robert Anello and Richard Albert explore the numbers and other recent patterns in the FCPA enforcement record regarding individuals, and discuss possible reasons for the decline.

Is FCPA Individual Enforcement at Odds With Government Rhetoric? (pdf | 118.67 KB)