FCPA Update 1 January 2019 Volume 10 Number 6 FCPA Update A Global Anti‑Corruption Newsletter In this issue: The Year 2018 in Review: 2 United States 30 United Kingdom Continued Globalization of Anti-Corruption 44 France Enforcement 52 Germany During 2018, anti-corruption enforcement remained vigorous. The United States 57 Asia continued enforcing aggressively the FCPA. And a growing number of other 65 Latin America countries enacted their own anti-corruption laws, pursued high-profile investigations Click here for an index of and enforcement actions, and partnered with other authorities in multi-jurisdictional all FCPA Update articles inquiries. In this issue, we survey the past year’s most significant anti-corruption If there are additional developments in the United States, the United Kingdom, France, Germany, Asia, and individuals within Latin America. your organization who would like to receive FCPA Update, please email
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[email protected] Continued on page 2 www.debevoise.com FCPA Update 2 January 2019 Volume 10 Number 6 United States A. Overview Overall, there were eighteen corporate enforcement actions – the third most corporate actions in FCPA history – which included four declinations under DOJ’s Corporate Enforcement Policy. In relation to these 18 matters: • The United States collected over $1 billion in penalties, or more than $1.9 billion including the disgorgement that the SEC credited from Petrobras’s class action settlement. • When adding settlement payments to other countries that the U.S. authorities credited, total penalties exceeded $2.9 billion, representing the third largest sanction amount in the FCPA’s 40-year history.