5/8/18: In a Client Memorandum published on April 13 on its website, law firm Paul, Weiss, Rifkind, Wharton & Garrison LLP provides a review of FCPA enforcement and anti-corruption developments. The authors note a decline in enforcement actions consistent with Deputy Attorney General Rod J. Rosenstein’s statements that DOJ place greater emphasis on companies’ compliance programs and individual prosecutions rather than on corporate prosecutions. The authors review enforcement activity in by DOJ and SEC. Just as important, they dig into anti-corruption activities outside the US, which have ramped up rather than down.
