Anti-Corruption Enforcement Isn’t Going Away
For two decades, the Department of Justice and Securities Exchange Commission aggressively enforced the Foreign Corrupt Practices Act against companies and executives worldwide. Corporate FCPA resolutions have reached billions for single companies, while individuals have faced years of imprisonment. The DOJ has also pursued domestic corruption cases against those paying state and local officials for favorable government action.
The current administration has recalibrated FCPA enforcement priorities. We anticipate new focus on corruption that facilitates cartel activity, supports transnational criminal organizations, or impacts national security. The administration may also leverage the Foreign Extortion Prevention Act (FEPA), which allows prosecution of foreign officials who demand bribes from U.S. companies.
Despite this shift, businesses face continuing corruption risks from both U.S. and foreign authorities. Navigating these waters requires experienced counsel with deep understanding of enforcement trends.
Experience That Delivers Results
Treanor Devlin Brown brings exceptional anti-corruption credentials. Arlo Devlin-Brown formerly led the Public Corruption Unit for the U.S. Attorney’s Office in the Southern District of New York. Tim Treanor has earned national and global recognition for his anti-corruption expertise.
Together, our founding partners have represented numerous companies and individuals in significant FCPA matters and negotiated major enforcement resolutions. Our insight into DOJ and SEC priorities allows us to provide strategic guidance to clients facing corruption investigations or seeking to mitigate compliance risks before problems arise.