On 28 February, Wilmer Hale published a Client Alert which summarises key Latin America anti-bribery enforcement developments from 2019 and provides predictions for 2020. Also available is a webcast, in English and Spanish. It predicts that FCPA enforcement will continue to be a high priority for the DoJ and the SEC and that the level of FCPA enforcement activity in Latin America will remain at the high levels seen in recent years. It says that several trends that have been seen develop and evolve over the last few years look set to continue. For example –
- large cross-border investigations appear likely to feature heavily in 2020 enforcement activity once again;
- DoJ leadership continues to emphasise the prioritisation of individual prosecutions, suggesting that this will remain a focus for the its FCPA unit in 2020; and
- efforts by Latin American governments to pursue corruption cases within their borders seem likely to continue, with increased cross-border cooperation between prosecutors.
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