Welcome back to the podcast, bribes, swindle, or steel.

Today we're going to listen in on a great 2019 FCPA year-in review, presented by Jeff Clark.

Jeff is a partner with Wilkie Farron Gallagher and is presented at many trace events.

We're delighted to have him back on the

podcast. I apologize in advance for the audio quality, which gets a bit bumpy in a few places,

but stay with us. It doesn't last long. Here's Jeff.

2019 was, by any measure, a really strong year for enforcement. This was a very busy year. And if you look at the trend line

from 2016 to 2017 to 2018 to 2019, I think we can finally put to rest a notion that was discussed

when Donald Trump was elected president that somehow he or his administration would take their foot off the pedal

on FCPA enforcement as a matter of being perhaps more business-friendly or his own personal

distaste for the FCPA based on some remarks he had made years before he became president.

The reality is FCP enforcement is driven

primarily by career prosecutors and SEC staff. The dedication of resources

hasn't changed and therefore the enforcement rigor hasn't changed. This

reflects enforcement actions only against companies and again you can see

the same kind of trend line going up, not perhaps the most active

year of all time, but to be sure, an active year.

And what's interesting is corporate enforcement on the rise at the same time as we'll

see individual enforcement, particularly from DOJ, is on the rise at the same time as we'll see individual enforcement, particularly from DOJ, is on the rise.

DOJ's focus since 2016 or 2017 on prosecuting culpable individuals has not come at a cost to its corporate

enforcement program.

Enforcement actions initiated against individuals,

...