Conclusion
FCPA DIGEST January 2021 40
CONCLUSION
Although the DOJ and SEC brought fewer FCPA
enforcement actions in 2020 than in recent years, Airbus
and Goldman shattered the record for yearly aggregate
corporate penalties—bringing the total to more than
double the previous record year (2016). With a change in
administration around the corner and a potential shuffling
of U.S. enforcement personnel, it remains to be seen
whether we will see such blockbuster enforcement trends
in 2021.
