Welcome back to the podcast, bribes, swindle, or steel. I'm Alexandra Ragi. This will be our last

new podcast of 2019 for Christmas Day and New Year's Day will repost popular conversations

from the last few years, including my holiday favorite from a wine fraudster,

Rudy Carneyawan. But my guest today helps us wrap up 2019 with a great summary of some key

trends over the year. He's a senior partner at the boutique FCPA firm Steinman and Rogers,

Bill Steinman. Thank you for joining me, Bill. Oh, Alexandra, thank you so much for having me

and happy holidays. Why don't you just launch right in? What were some of the key themes this year?

I think there were four key themes this year, and I'll just start with the first one, which is

the FCPA has shown that it's here to stay. It continues to be a key priority for both the Department of Justice and the Securities and Exchange Commission. And indeed, 2019 was a record-setting year. We had over $2.9 billion imposed against companies and individuals. Of course, that number can fluctuate a little bit,

depending on how you calculate double counting and the like, but I think $2.9 billion is the right number.

We also saw a record number of enforcement actions brought against individuals, primarily,

but not exclusively by the DOJ. By my counting, there were 32 individual

enforcement actions, which include new indictments or charges, guilty pleas in existing cases,

trials resulting in guilty verdicts, and then sentencing. We also have a robust backlog of public companies that have

announced FCPA enforcement actions. I think we're at about 116. And we've also had 16 companies in

2019 come forward and report new internal FCPA investigations.

I think the important point about this is there's a lot of wishing and hoping that this

period of heightened enforcement, which is now 15 years old, would wane at some point.

And it seems quite stubborn.

It seems extraordinarily bipartisan.

We entered this period under George W. Bush.

It continued under President Obama, and it shows no signs of easing under the current administration.

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