If you want to know what the Justice Department’s priorities are, all you have to do is follow the resources (or as we say from the Watergate days — follow the money). DOJ’s FCPA resources are now being allocated in large part to trial work. That leaves less time to manage the voluntary disclosure process, to move internal investigations being conducted by outside counsel, and to wrap up cases and get all the internal approvals needed before filing a settlement or deciding not to prosecute. The number of settlements and the fines collected have dropped significantly during this year.
‘Enforcement 40’ for 2020
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