FCPA Enforcement, Compliance Trends During the Pandemic



In this article, John Davis and Ivo Ivanov review recent Foreign Corrupt Practices Act (FCPA) compliance and enforcement trends and discuss the impact of the coronavirus pandemic on FCPA-related matters. The authors wrote that "a review of enforcement data and trends for the year so far makes clear that the pandemic has impacted and will continue to affect the agencies' FCPA activities. The impact of the pandemic and the related lockdowns on FCPA-related investigations has been felt in some - but not all - relevant areas." They noted, however, that "[t]he DOJ and the SEC have continued to message publicly that the agencies' commitment to FCPA enforcement has not subsided," stating "FCPA enforcement numbers through prepandemic 2020 largely supported this official rhetoric."