This article appeared in Business Crimes Bulletin, an ALM publication covering financial and white-collar crime. For Corporate Counsel, Litigators, Managing Partners, Defense Attorneys. Visit the website to learn more.

Editor's note: In last month's newsletter (see http://bit.ly/2q2ZSo5), the authors began discussion of whether we should expect changes in enforcement of the Foreign Corrupt Practices Act (FCPA) in the Trump era. Trump once called application of the law to deals done in countries where bribery is the cultural norm “absolutely crazy.” But that was when he was purely a businessman, and a private citizen. What about now?

Enforcement Efforts By Other Countries

As the penalties being extracted by the United States from multinational corporations for violations of anti-corruption statutes have skyrocketed in recent years, an increasing number of other countries have begun to pass or enhance their own laws prohibiting, among other things, bribery of foreign officials, and have increased the financial penalties applicable to businesses that violate those laws. For example, Dutch law enforcement's ability to extract large penalties for violations of its anti-bribery laws was expanded immensely by a new law enacted on Jan. 1, 2015, that increased the maximum sanctions available to be imposed on Dutch companies to a cap of 10% of the violating company's annual turnover.