31
CONCLUSION
Although the DOJ and SEC brought only four combined
corporate enforcement actions in 2021, the "individuals"
side of the enforcement coin saw plenty of activity. With
the DOJ charging twenty-three individuals and with
meaningful developments in existing cases against a
number of 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 year 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 few corporate
enforcement actions this year are likely no bellwether of
a new norm of limited enforcement.
