2019 FCPA Enforcement Highlights and Trends
Enforcement of the FCPA remained aggressive in the third year of the Trump Administration. In 2019, the SEC and DOJ imposed a record setting $2.9 billion in penalties. Although recent settlements largely appear to have been initiated under the Obama Administration, the Trump Administration has maintained Obama-era anti-corruption initiatives and policies. In a guest article, partners Jeremy Zucker, Darshak Dholakia and Hrishikesh Hari, and law clerk Tanya K. Warnke analyze 2019’s enforcement actions and SEC, DOJ and CFTC policy developments and enforcement trends.
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