FCPA Spring Review 2021

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In the first quarter of 2021, the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) each announced one corporate Foreign Corrupt Practices Act (FCPA) enforcement action – related dispositions involving German financial services company Deutsche Bank AG. The first quarter of 2021 saw no individual FCPA enforcement actions, although the DOJ announced bribery-related money laundering charges against two individuals, and multiple individuals received sentences or fines for FCPA charges that had been previously resolved. Two individuals—both employees of foreign state-owned entities—also pleaded guilty to money laundering charges in connection with international bribery schemes during the first quarter, and the DOJ unsealed a similar money laundering plea agreement in March.

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