In 2021, the number of publicly resolved Foreign Corrupt Practices Act (FCPA) cases was relatively low compared with previous years, but there were numerous interesting developments, and enforcement activity going forward into 2022 appears to be trending upwards. Of note, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced the lowest number of corporate resolutions in more than a decade. At the same time, in the first year of the Biden administration, enforcement authorities consistently maintained that enforcement remains active, and a number of policy announcements and ongoing DOJ and SEC proceedings indicate that the volume of enforcement actions is likely to increase in 2022. The new administration's anti-corruption priorities and its release of several substantial policy initiatives toward the end of 2021 further suggest significant and growing enforcement efforts going forward.
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