When The United States has hit pause on Foreign Corrupt Practices Act (FCPA) enforcement—it left many asking whether Europe will now be stepping up to lead the global anti-corruption charge. In this episode of Corruption, Crime and Compliance, Michael Volkov explores how European prosecutors are responding to the enforcement gap, why multinational companies can’t afford to slow down their compliance efforts, and how both state-level and international initiatives are reshaping the future of anti-bribery law.
You’ll hear him talk about:
- The launch of a new International Anti-Corruption Prosecutorial Task Force formed by the UK, France, and Switzerland, designed to intensify cross-border enforcement and cooperation in bribery and corruption cases.
- The task force’s formation as a direct response to the U.S. enforcement pause, signaling that European agencies are prepared to take a more prominent role in prosecuting international corruption, especially involving multinational corporations.
- California’s bold move to pursue foreign bribery under its Unfair Competition Law (UCL), reinforcing that FCPA violations remain prosecutable at the state level despite federal hesitation.
- A continued commitment by global companies to maintain strong compliance programs, reflecting awareness that international and local enforcement can still pose serious legal and financial risks.
- The unexpected dismissal of the long-running FCPA case against Cognizant executives, contrasted with the DOJ's decision to move forward with prosecutions in other high-profile cases, suggesting a selective enforcement pattern under current policy shifts.
- A landmark case by the UK Serious Fraud Office (SFO), charging a company with failure to prevent bribery—a first for the SFO to bring such a case before a jury, potentially setting a new standard for corporate liability in the UK.
Resources
Michael Volkov on LinkedIn | Twitter
The Volkov Law Group