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A Buffet Of 2016 FCPA Enforcement Statistics

buffet

With much rhetoric floating around regarding the Foreign Corrupt Practices Act and with many creative and haphazard counting methods employed by certain FCPA Inc. participants, it is instructive to take a look at actual statistics.

FCPA Professor has been the place to visit this month for in-depth 2016 Foreign Corrupt Practices Act enforcement statistics as well as comparisons to historical statistics.

If you missed the daily posts, no worries.

This post consolidates in one place the statistics recently published on FCPA Professor.

This post highlights the origins of 2016 FCPA corporate enforcement actions. Voluntary disclosures comprised 37% of 2016 enforcement actions with a running five year average of 49% of DOJ corporate actions and 41% of SEC corporate actions.

This post highlights how the gray cloud of FCPA scrutiny lasted too long in 2016. Specifically, 4.25 years was the median length of time companies that resolved FCPA enforcement actions in 2016 were under scrutiny.

This post highlights various facts and figures from corporate FCPA actions brought by the DOJ in 2016 including: settlement amounts and specifics, resolution vehicles, monitors, and other categories.

This post highlights various facts and figures from corporate FCPA actions brought by the SEC in 2016 including: settlement amounts and specifics, resolution vehicles, and other categories.

This post aggregates corporate FCPA enforcement in 2016 with a comparison to historical averages.

This post highlights SEC individual FCPA enforcement actions from 2016 as well as historically. Of the 24 corporate SEC FCPA enforcement actions from 2016, only 7 (29%) have involved, at present, related SEC charges or findings against company employees. Since 2006, only 20% of SEC corporate actions have involved related SEC charges or findings against company employees.

This post highlights DOJ individual FCPA enforcement actions from 2016 as well as historically. Of the 13 corporate DOJ FCPA enforcement actions from 2016 0 have involved (at least yet) related DOJ criminal charges against company employees. Since 2006, only 23% of DOJ corporate actions have involved related DOJ charges against company employees.

This post highlights the strange public-private divide when it comes to DOJ individual prosecutions. In short, a DOJ FCPA enforcement against a private business organization is three times more likely to have a related DOJ FCPA criminal prosecution of an individual than a DOJ FCPA enforcement action against a publicly traded corporation.

This post highlights the alleged “foreign officials” from 2016 corporate enforcement actions. Of the 27 enforcement actions 21 (78%) involved, in whole or in part, employees of alleged state-owned or state-controlled entities (“SOEs) with 7 of the 21 (26%) actions involving, in whole or in part, individuals associated with foreign health care systems.

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