The FCPA and AML Statutes: Prosecutors Increasingly Combining Charges, to Great Effect

Although criminal prosecutions under the Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. (FCPA) and the U.S. anti-money laundering (AML) laws have developed differently over the years, a review of recent enforcement actions reveals that prosecutions under these criminal schemes have started to converge. Federal prosecutors are increasingly combining charges under the Foreign Corrupt Practices Act of 1977, as amended, 15 U.S.C. §§ 78dd-1, et seq. ("FCPA") and the U.S. anti-money laundering ("AML") laws to reach more defendants and achieve greater success in their criminal prosecutions.