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Global anti-corruption enforcement numbers going up

Tom Fox | February 14, 2017

As dramatic as the increase in Foreign Corrupt Practices Act fines and penalties were in 2016, one of the more important themes for the year was the globalization of enforcement. By the end of 2016, international enforcement numbers had reached a staggering level with Odebrecht/Braskem, and then in the first month of 2017 with the Rolls-Royce resolution. I want to discuss what are some of the factors leading to this dramatic upswing in fines and penalties for anti-corruption and bribery enforcement. The Justice Department and Securities and Exchange Commission have worked quite diligently to increase professionalism around anti-corruption enforcement in jurisdictions outside the United States. At the ACI-2016 National FCPA conference last November, Kara Brockmeyer, chief of the FCPA unit, Division of Enforcement at the SEC, and Daniel Kahn, Chief of the FCPA unit fraud section, Criminal Division at the Justice Department, articulated an additional reason, which was the increase in...

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