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CONCLUSION
Although the DOJ and SEC brought only two combined
corporate enforcement actions in the first half of 2021, the
'individuals' side of the enforcement coin saw plenty of
activity. With the DOJ charging thirteen individuals and
with meaningful developments in existing cases against
fifteen individuals, including guilty pleas and sentences
imposed, it appears the U.S. enforcement agencies
continue to work in spite of the political shuffle of
administration and the lingering impact of the coronavirus
outbreak. Corporate investigations have ramped up as
the world begins to reopen, with nearly a dozen
companies publicly announcing in the last few months
that U.S. investigators have inquired into their conduct
abroad. It remains to be seen whether this work will lead
to enforcement actions of the magnitude seen last year,
but the sole corporate enforcement action this year is
likely no bellwether of a new norm of limited enforcement.
