FCPA Year-in-Review: 2024 Developments and Predictions for 2025

FCPA Year-in-Review: 2024 Developments and Predictions for 2025

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Foreign Corrupt Practices Act (FCPA) enforcement activity increased overall in 2024, with a notable uptick in Department of Justice (DOJ) enforcement actions compared to 2023, despite a decrease in public Securities and Exchange Commission (SEC) enforcement actions. Collectively, the DOJ and SEC brought a total of 38 enforcement actions, including 14 corporate and 24 individual enforcement actions. The January 2025 change in administration brings some uncertainty as to the prioritization of anti-corruption enforcement going forward. Despite President Donald J. Trump’s prior vocal criticism of the law,  FCPA enforcement during Trump’s first term was robust, averaging more than 40 DOJ enforcement actions and 14 SEC enforcement actions per year between 2017 and 2020. Early actions in President Trump’s second term, however, indicate that priorities may be recalibrated this time around, and it is unclear how these changes may affect anti-corruption and other white collar enforcement efforts.

Contents include:

  1.   Introduction
  2.   2024 Enforcement Trends and Priorities
  3.   Key Policy Announcements
  4.   Key Investigation Related Developments
  5.   Notable Individual Resolutions
  6.   Key Legal Developments
  7.   Collateral Actions
  8.   International Legal Developments
  9.   Conclusion

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