USA Law and Practice Contributed by: Eric Bruce and Justin Simeone, Freshfields US LLP
9.2 Likely Changes to the Applicable Legislation of the Enforcement Body
and SEC enforcement approaches, and increased tracking of debarments stemming from bribery- related enforcement actions by foreign governments and multilateral financial institutions. In an October 2022 follow-up report, the OECD found that, since the adoption of its original report in 2020, the US had fully or partially implemented nearly eight out of its nine recommendations. The European Court of Human Rights and GRECO In December 2023, the Council of Europe’s Direc - torate General for Human Rights and Rule of Law: Group of States against Corruption (GRECO) issued a report assessing anti-corruption laws and practic - es. The report noted areas where the USA had made progress since previous evaluations, but it identified additional points for improvement, including greater accountability for the President and Vice-President, greater transparency of lobbyists, more risk evaluation relating to personnel changes in the Executive branch, and a dedicated FBI anti-corruption strategy.
US government authorities frequently revise enforce - ment policies and priorities, which can affect the scope and practice of federal anti-corruption laws. It is possible, for example, that recent DOJ pilot pro - grammes on corporate whistle-blower awards as well as compensation incentives and clawbacks may become permanent programmes in the future. Fur - thermore, DOJ leaders have signalled an intention to focus greater attention to how companies mitigate the risk of misusing artificial intelligence and other disrup - tive technologies, starting with recent updates to the ECCP on this topic.
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