The first quarter of 2018 was relatively slow in terms of the number of Foreign Corrupt Practices Act (FCPA) cases resolved by the government. However, regulators note that FCPA enforcement will continue to be a priority throughout the year.
Deputy Attorney General Rod Rosenstein reinforced The Department of Justice’s (DOJ) commitment to investigating, prosecuting, and eradicating corporate fraud and the importance of compliance programs ingrained in corporate culture. In a keynote address at the 32nd Annual ABA National Institute on White Collar Crime on March 2, 2018, Rosenstein emphasized that “the Department of Justice stands for the principle that every American deserves equal protection under the rule of law.” He talked about the pursuit of truth and how truth may not always match preconceptions. Rosenstein went on to highlight some of the DOJ’s accomplishments over the past year, including the launch of the new FCPA enforcement policy, which has now been incorporated into the U.S. Attorneys’ Manual.
At the same conference, SEC Co-Director of Enforcement Steve Peikin suggested that the SEC’s FCPA enforcement policy will not be similar to the DOJ’s policy. This is a result of the dramatically different consequences in the SEC civil context.
To learn more about the specific enforcement activity from Q1 2018, download the full report or reach out to one of our FCPA experts.
Special thanks to Andrew Lind, who contributed to this report.