By Adam Turteltaub
With a constant stream of enforcement actions related to the US Foreign Corrupt Practices Act (FCPA), it can be difficult to read the tea leaves and discern the patterns.
Laura Perkins of Hughes Hubbard & Reed is co-author of the firm’s Annual FCPA & Anti-Bribery Alert, which gives her perspective on what all those individual cases are pointing to. In this episode of the Compliance Perspectives Podcast she reports that the biggest trend in 2018 was the growth in international enforcement and cooperation in anti-bribery laws. More and more it’s not just the US Department of Justice (DOJ) or the UK Serious Fraud Office prosecuting on its own. Enforcement authorities from across multiple jurisdictions are working together.
A second trend is a significant increase in individual enforcement actions. The DOJ seems to have made good on its word to focus on the people, not just the companies they work for.
Listen in as she discusses these trends, the pace of prosecutions, the state of the DOJ’s Pilot Program, and how GDPR is affecting internal investigations.