TRACE Global Enforcement Report: 2019 slow year for enforcement actions

The 2019 Global Enforcement Report offers both graphic and textual analyses of investigations and enforcement actions concerning the bribery of government officials from the enactment of the U.S. Foreign Corrupt Practices Act in 1977 through 31 December 2019:

  • 2019 was a relatively slow year for enforcement actions in transnational bribery cases. Both global and U.S. enforcement numbers in cases involving bribery of foreign officials dropped, with a 19% decrease in U.S. enforcement actions and a 45% decrease in non-U.S. enforcement actions—though the resulting enforcement levels were not out of line with historical trends of anti-bribery enforcement. 

  • While the financial services industry remained a focus for U.S. anti-bribery enforcement authorities, companies in the extractive industries faced the most U.S. investigations in 2019. There was also an increase in U.S. investigations into bribery of foreign officials in the aerospace, defense and security industries. 

  • In non-U.S. investigations, extractives remained the most investigated industry, followed by engineering/construction and aerospace/defense/security. 

  • As of the end of 2019, Brazil was conducting the most investigations concerning alleged bribery of domestic officials by foreign companies, followed by India and China

  • China again had the highest prevalence of alleged bribery by foreign companies, with Chinese officials being the alleged recipients of bribes in more than 110 enforcement events since 1977. Iraq has the next-highest number of enforcement events, followed by Brazil. 

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