FCPA Year in Review (2024)
Bribe, Swindle or Steal
Alexandra Addison-Wrage of TRACE International
4.9 • 582 Ratings
🗓️ 12 February 2025
⏱️ 43 minutes
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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
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| 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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