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Bribe, Swindle or Steal

FCPA Year in Review (2024)

Bribe, Swindle or Steal

Alexandra Addison-Wrage of TRACE International

Business, News, Business News

4.9582 Ratings

🗓️ 12 February 2025

⏱️ 43 minutes

🧾️ Download transcript

Summary

This podcast is based on TRACE's recent Year in Review webinar with Kate Atkinson. Kate is a Member and the Chair of Miller & Chevalier, based in their DC office, and she reviews for us the FCPA highlights for 2024.

Transcript

Click on a timestamp to play from that location

0:00.0

Welcome back to the podcast, Bride, Swindler Steel. I'm Alexandra Rogge. For today's podcast, we're

0:12.8

listening in on Trace's Year in Review webinar with Kate Atkinson. Kate is a member and the chair

0:18.4

of Miller and Chevalier based in their DC office.

0:21.7

Here's Kate.

0:23.0

I think there's an interesting mix of policy, legislative, and enforcement activity to talk about in 2024

0:31.9

and obviously some crystal ball work that we can do at this stage of the brand new Trump administration.

0:39.5

We'll march through these in terms of just a overview of what happened in 2024 from an enforcement

0:45.0

perspective, legislative and policy updates in what has been a quite active policy administration

0:51.9

under President Biden, and then switch to what's next, sort of anticipated

0:56.9

enforcement in 2025, sort of early tea leaf reading from the Trump administration. And then just a

1:03.5

quick wrap up that I hope you all can use as you go back out to your constituents in your various companies and organizations.

1:13.6

Initiation of enforcement actions in 2024. So these are public. Never tells the whole story because

1:21.3

some actions are filed under seal. Always good to keep that in mind. There are tend to be cases

1:26.7

in the pipeline that we are not aware of just based on what's publicly disclosed.

1:32.3

So in 2024, there were 26 total cases initiated, 17 by DOJ, 9 by the SEC, ever so slight an increase over 2023, during which time I think particularly DOJ came under some

1:46.7

criticism for just kind of a slow pace. They were quite explicit in their public statements that

1:54.0

they were seeking to be more active in 2024, but also sort of noting the complexity of the cases that they are bringing.

2:03.9

This total of 26 is still well below a 10-year average of 36, so I think still not at a level

2:10.2

of enforcement activity that you saw in prior years. I think what's interesting is DOJ under the

2:17.4

Biden administration in the fraud section

2:19.6

in particular were very focused and routinely commented on their desire to bring what they

2:24.7

called impactful cases. And we'll see some of the impacts that they had in mind as we go through

...

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