In following the Justice Department and the Securities Exchange Commission FCPA enforcement actions, I am always reminded of the popular phrase — “reading the tea leaves.” (or “tasseography,” a fortune-telling method based on tea leave patterns in tea sediments). Despite a slow initial year in 2021, the Biden Administration’s stamp and push on FCPA enforcement is becoming clear. Keep in mind, DOJ and SEC officials have promised a new, tougher approach to FCPA enforcement. Change in government enforcement policies, and results take time. However, no one expected the changes to take this long. In addition, the initial enforcement push has raised some interesting questions concerning the specific steps taken by enforcement officials. In looking at the most recent FCPA enforcement actions (i.e., Stericycle, Glencore, and Tenaris), there are significant new trends and some important issues. In this episode, Michael Volkov reviews the important trends and issues surrounding FCPA Enforcement in 2022.
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