CASE STUDY

The DOJ’s Revised Corporate Enforcement Policy and Your Compliance Path Forward: The Most Recent Enforcement Actions What They Reveal Between the Lines

June 14, 2023 3:45pm

Pamela Davis
Partner, Chair FCPA & Anti-Corruption Team
Winston & Strawn LLP

Scott Joiner
Partner
Latham & Watkins LLP

Brendan Kelleher
Partner, Chief Compliance Officer & Head of Enterprise Risk
SoftBank Group International

  • In 2022, there were 10 FCPA-related settlements, totaling $924 million, one of the higher totals in recent years. Additionally, DOJ has been active in issuing guidance on FCPA-related matters.
    • A holistic view of the enforcement landscape, and settlement trends
    • When and how a strong compliance culture served as a remediating or enhancing factor
    • Meeting DOJ expectations for third-party monitoring procedures