Hogan Lovells Global Bribery & Corruption Outlook 2024 predicts a year of shifting enforcement dynamics as elections take place across the world

Hogan Lovells Global Bribery & Corruption Outlook 2024 predicts a year of shifting enforcement dynamics as elections take place across the world

Press releases | 24 January 2024

Los Angles, London - 24 January 2024 – Voter power will have a major impact on 2024, as elections take place in jurisdictions that make up almost half the world’s population – around 4 billion people. The economic and geopolitical effects of this multinational voting spree will shape the world for years to come. According to the latest report by the Investigations, White Collar and Fraud (IWCF) practice at global law firm Hogan Lovells, it will likely mark a shift in enforcement dynamics in many key jurisdictions. This is set against a backdrop of continued conflicts in the Middle East and Eastern Europe, which provide a hotbed for bribery and corruption to thrive.

In the U.S., while elections won’t take place until November, “compliance teams would be wise to keep an eye on campaign rhetoric from both sides of the political sphere, as they will guide teams on the likely direction of the Department of Justice (DOJ) for 2025 and beyond,” said Hogan Lovells partner Stephanie Yonekura, Global Leader of IWCF. “For 2024, DOJ has already signaled its priorities: timely self-disclosures, compensation clawbacks, and ephemeral messaging, so companies should be keeping these top of mind in evaluating their compliance programs and cooperation decisions,” added Yonekura.

The stakes are high in the UK too, where there could be a change of political leadership after 14 years. London partner, Liam Naidoo, Deputy Leader of the IWCF practice, and an editor of the Outlook said “new legislation in the shape of the Economic Crime and Corporate Transparency Act coupled with a shake-up at the Serious Fraud Office could provide the shot in the arm UK prosecutors have long called for in their crack down on economic crime.” 

Against this backdrop, the Outlook highlights trends in how regulators and prosecutors are examining potential corruption. One area of focus continues to be Environmental, Social, and Governance (ESG), where the regulatory landscape is evolving to put a greater focus on governance. Naidoo said “we see cases where human rights and environment issues lead to investigations into alleged bribery, so it’s crucial that companies look at compliance holistically.”

Everything is connected

The Outlook highlights compliance efforts across the globe, including the EU, the Middle East, APAC, and Latin America. 

Hogan Lovells partner, Dr. Philip Matthey, based in Munich, observes that “the implementation of the EU Whistleblowing Directive into national law is challenging for multinational companies since they need to meet partly inconsistent requirements when setting up whistleblowing systems and internal investigation processes.” Then there’s the significant hurdle of “creating effective reporting mechanisms and authorities,” added Matthey.

In Southeast Asia, authorities are fighting corruption across the region. Vietnam has grappled with an historic US$12.4 billion banking embezzlement scandal, reportedly the largest corruption scandal in Southeast Asian history. Malaysia and Singapore have also grappled with government related corruption.

“These crackdowns signal a commitment by Southeast Asian nations to build a clean business environment,” said Nick Williams, a partner in the firm’s Singapore office. “Indeed, these actions may help spur business development and enhance the region’s appeal as a major player in the global supply chain. With potential leadership transitions in multiple countries, it remains to be seen whether anti-corruption policies and efforts will continue to step up this year.”

Topics covered in the Outlook are:
  • Southeast Asia’s crackdown on emerging government corruption, among other trends
  • Compliance challenges in Latin America’s automotive sector
  • After 10 years of the Brazilian anti-corruption law, what lies ahead?
  • Corruption and ESG – more of the same
  • Whistleblowing Directive: Navigating challenges for multinational companies in EU implementation
  • Strengthening your anti-bribery and corruption toolkit with a focus on AML compliance
  • Life sciences beware as China tackles health care corruption
  • The UAE and Saudi Arabia – taking on corruption
  • DOJ’s focus on immediate self-disclosures, clawback and ephemeral messaging apps
  • DOJ announces policy for self-disclosures on criminal misconduct of acquired companies, with a catch
  • The fight against economic crime in the United Kingdom enters a new phase
The Outlook can be found here