DOJ’s 2019 Enforcement Activities Demonstrate a Continued Commitment to FCPA Enforcement

Enforcement of the FCPA is poised for another record-shattering year in 2019. But even as the penalties collected in foreign bribery cases continue to rise, there appears to have been a notable evolution in the approach that the DOJ is using when pursuing such cases. In a guest article, Sullivan & Cromwell partner Ann-Elizabeth Ostrager discusses what the DOJ’s recent activities say about the Department’s priorities. See “Analyzing the DOJ’s New Evaluation of Corporate Compliance Programs” (May 15, 2019).

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