Anti-Corruption Enforcement and Compliance: Where We Stand Now
Compliance & Ethics Professional Magazine
In this article, Joshua Drew and Mena Sawyer, along with their co-author Jordan Segall, Senior Counsel for Ethics & Compliance at Xylem, explore the anti-corruption enforcement landscape shaped by new policies and priorities, and the ongoing importance of effectively mitigating Foreign Corrupt Practices Act (FCPA) risk. "[C]ompanies with business operations that present corruption risk are well-advised to stay the course, not alter their compliance risk calculus, and remain vigilant. While enforcement priorities are shifting in the U.S., anti-corruption enforcement by authorities outside the U.S. remains robust," the authors wrote. "And even as DOJ and SEC revisit their anti-corruption enforcement approach, such enforcement can be pursued through other avenues, including federal money-laundering statutes or state statutes such as California's Unfair Competition Law. DOJ and SEC approaches may also change and become enforceable under an extended 10-year statute of limitations if the recently proposed FCPA Reinforcement Act becomes law."