In its nearly 40 years of existence, there have been numerous SEC Foreign Corrupt Practices Act enforcement actions against issuers that did not also involve a DOJ component.
As highlighted below and also last month in this very similar post involving Nortek and Akamai Technologies, there is a simple reason for this. Not all civil SEC FCPA enforcement actions involve viable criminal charges against an issuer.
For most of the FCPA’s history, the DOJ never saw the need to highlight the FCPA cases it did not bring. But in April 2016 the DOJ announced its so-called FCPA “Pilot Program” and went into public relations marketing mode.