Over the past years, anti-money laundering due diligence and compliance has continuously intensified and remained to be among the ever-evolving challenges for businesses. Furthermore, the rapid developments brought by financial technologies have opened cyber and insider threat vulnerabilities, adding up to the risks that regulators and financial institutions need to address.
The aggressive enforcement of the Foreign Corrupt Practices Act (FCPA) continues to be a priority for the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC). Seven enforcement actions were made during the third quarter of 2019 with about $78.5 million in disgorgement and penalties. Top areas of enforcement include corporate compliance individual accountability, international cooperation, and multi-jurisdictional coordination.
With the new administration and several notable issues continuously emerging in the backdrop, an increase in enforcement actions is expected to hound the Foreign Corrupt Practices Act (FCPA) landscape bringing both complexity and new compliance challenges to businesses. Significant developments affecting large corporate FCPA settlements, multi-jurisdictional FCPA matters, and increased individual enforcement need crucial consideration and anticipation from companies and their counsel.