Hogan Lovells Predicts Heightened Enforcement Activity for 2015 in Annual Global Bribery and Corruption Review

LONDON, 12 February 2015 - Hogan Lovells has launched its fifth annual Global Bribery and Corruption Review, which predicts a spike in aggressive enforcement tactics across the globe  in 2015 and an increased focus on emerging markets.

The review, which has been co-edited by Hogan Lovells partners Stuart Altman and Michael Roberts, sets out the key issues for international organisations to monitor in 2015 and looks back at recent important developments in anti-bribery and corruption regulation and enforcement around the world. 
The review forecasts that 2015 will see:

  • Heightened scrutiny around hiring practices by major banks and multinational corporations
  • An increased reliance on administrative actions by the Securities and Exchange Commission (SEC) in order to bypass the courts – an area that has caused the SEC some complications in the past.
  • Africa and other emerging markets will come under the spotlight, with a spike in reported instances of bribery and corruption cases and a renewed effort to combat it. The review highlights that five out of the 10 countries, which scored as 'most highly corrupt' in Transparency International’s 2014 Corruption Perceptions Index, were in Africa.
  • An ongoing soar in aggressive enforcement actions by the Department of Justice (DOJ) for Foreign Corrupt Practices Act (FCPA) violations. The review highlighted that 2014 was a record year, with some of the most high-value FCPA cases in history.
  • The UK government look to abolish the Serious Fraud Office (SFO) and transfer corruption enforcement to the newly established National Crime Agency.

The review also looks at other markets such as India, Russia, the Middle East and Mexico. Mexico, where the firm now has expanded capabilities after its combination with Barrera, Siqueiros y Torres Landa (BSTL),  still lags behind many peer countries being rated 103 out of 175 on Transparency International's 2014 Corruption Perception Index.

The review predicts that the imminent creation of the National Anti-corruption System (NAS) in Mexico will see a tougher crackdown on corruption at all levels. It also closely analyses how China has drastically increased efforts to fight corruption, both within its own government and amongst companies active in the country and what we can expect to see emerge in 2015.

 Hogan Lovells partner Stuart Altman commented:
"Two key developments defined 2014 enforcement actions, the SEC’s use of administrative proceedings to bypass the courts, and the DOJ’s use of settlements to impose policy changes that are usually reserved for Congress. The coming year ahead will be an active and interesting one, which will see an increase of old-school enforcement actions across the globe."

Crispin Rapinet, head of Hogan Lovells’ Investigations, White Collar and Fraud practice group, added:
With the increased pace of business activity across the continent and the varied level of effort in fighting corruption, it is likely that Africa will continue as an active arena in the battle against bribery and corruption for the near future."

A full copy of The Global Bribery and Corruption Review 2014 can be found here.

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