COMPLIANCE
2022 Anti-Bribery and Corruption Enforcement Outlook By STEPHANIE YONEKURA AND RUPINDER GARCHA
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n 2021, the Biden administration laid the foundation for its anti-corruption strategy. This coincided with similar initiatives announced by foreign governments and intergovernmental organizations. In 2022, we anticipate re-energized efforts to implement anti-corruption measures, and increased enforcement and prosecution activities around the world. This article discusses recent global enforcement developments and offers recommendations for mitigating risk. In June 2021, the United Nations held a special session to reinvigorate political will to fight corruption. The G7 issued a statement of support, and identified concrete actions to detect and
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root out corruption. For example, the G7 highlighted their efforts to strengthen registries of company beneficial ownership information, and prevent real estate property transactions from being used to launder money or to finance criminal activity. Recently, in connection with the war in Ukraine, the G7 acted quickly to ban Russia from the SWIFT international banking system. Additionally, last June, President Biden established corruption as a threat to U.S. national security and called on an interagency body to review the government’s ability to combat corruption. In the last quarter of 2021, the Biden administration released the U.S. Strategy on Countering
Corruption, and the Department of Justice issued the Monaco Memo, strengthening corporate criminal enforcement policies. The memo conditioned the receipt of corporate cooperation credit on the disclosure of information about all potentially relevant individuals involved in wrongdoing; directed prosecutors to consider the complete criminal, civil and regulatory record of corporate defendants in resolving cases; and provided prosecutors with the freedom to impose independent monitors. In December 2021, the United States, U.K. and E.U. launched the Inter-Parliamentary Alliance against Kleptocracy, which promotes enforcement of strong BACK TO CONTENTS
