January 7 2025 -- 2024 FCPA Enforcement and Compliance Review

For the Justice Department and the SEC, 2024 was an interesting year in FCPA enforcement and compliance. With the new Trump Administration taking over in 2025, DOJ's commitment to FCPA enforcement may be questioned. This past year included several significant FCPA enforcement matters -- Raytheon, Trafigura, Gunvor and SAP, along with a number of significant FCPA cases again st individuals. Meanwhile, the SEC continued its steady enforcement of mid-size cases, along with major cases where it had jurisdiction.
DOJ also issued new compliance guidance, established its own whistleblower program, and continued to push on ethics and compliance programs to evolve and improve, especially with respect to emerging technologies and artificial intelligence.