CASE STUDY
The DOJ’s Revised Corporate Enforcement Policy and Your Compliance Path Forward: The Top 5 Most Critical, Recent Cases and What They Reveal Between the Lines
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