FCPA DIGEST July 2020 40
CONCLUSION
Although the DOJ and SEC brought a relatively low number of
FCPA enforcement actions in the first half of 2020, Airbus brought
the yearly aggregate corporate penalties to a record high—with
six months to spare. The first half of 2020 has been an exception
to recent enforcement trends due, largely, to the COVID-19
pandemic and unprecedented disruption of business as usual. It
remains to be seen whether FCPA enforcement actions pick up in
the second half of the year.
