3 FCPA Enforcement Predictions For 2019



In this article, James Tillen and Ann Sultan analyze 2018 enforcement trends to make three predictions for 2019: 1) the Department of Justice (DOJ) will not make any major policy announcements in 2019; 2) the DOJ and Securities and Exchange Commission (SEC) will continue to wrap up long-running investigations; and 3) investigations in Latin America will continue to lead to U.S. actions. "We predict that the ripple effects from Operation Car Wash and other cases in Latin America will continue to reverberate and expand in 2019 leading to further U.S. enforcement actions," Tillen and Sultan wrote.