Foreign Corrupt Practices Act in 2019
Monday, February 4, 2019 at 10:19AM
John A. Schwab
As we enter 2019, the government’s enforcement of the Foreign Corrupt Practices Act (“FCPA”) shows no signs of slowing down. The U.S. Department of Justice and U.S. Securities and Exchange Commission have joint responsibility to enforce the FCPA. DOJ’s FCPA enforcement is handled through the Criminal Division’s Fraud Section. The SEC’s Enforcement Division has a specialized unit focusing on FCPA enforcement. Helpful resources on this topic include the DOJ’s Corporate Enforcement Policy found here and the SEC’s Resource Guide found here.

FCPA enforcement can take a variety of forms.  As highlighted below, violations of the FCPA’s “books and records” provisions are often handled short of criminal charges, but FCPA bribery allegations are often handled via criminal charges. Here are a few of the governments resolutions in late 2018:
With results such as these, the government undoubtedly views its return on investment of time and resources as positive. Knowledgeable and experienced counsel is critical in defending against such actions – not only for corporate entities, but for individuals as well.
Article originally appeared on White-Collared (
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