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Corporate FCPA Enforcement In 2016 Compared To Prior Years

Statistical Analysis

Previous posts this week (here and here) separately analyzed DOJ and SEC corporate Foreign Corrupt Practices Act enforcement in 2016.

Viewing FCPA enforcement statistics this way is useful and informative given that the DOJ and SEC are separate law enforcement agencies and different issues may arise in DOJ and SEC FCPA enforcement actions.

By way of review, below are the 2016 DOJ and SEC FCPA enforcement statistics compared to prior years.

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The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2016

Gray Cloud

This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2016.

Continuing with the FCPA statistical feast, this post follows the chronology of FCPA scrutiny to FCPA enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.

That is – FCPA scrutiny simply lasts too long. Specifically, as highlighted below, 4.25 years was the median length of time companies that resolved FCPA enforcement actions in 2016 were under scrutiny.

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The Origins Of 2016 Corporate FCPA Enforcement Actions


2016 was a record-breaking year for Foreign Corrupt Practices Act enforcement.

Largest number of corporate enforcement actions in FCPA history – check. Largest aggregate corporate settlement amounts in FCPA history – check. These statistics will all be profiled in much greater detail in future posts.

Before an FCPA enforcement action is announced however, FCPA scrutiny must first originate.

This post, the first in a weeks-long FCPA statistical feast on FCPA Professor, highlights the origins of 2016 corporate enforcement action.

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2016 FCPA Enforcement Sets Another Record – Largest Overall Corporate Settlement Amounts

record breaker

As highlighted in this prior post, 2016 had already become a record-breaking year on September 30th in terms of the number of corporate Foreign Corrupt Practices Act enforcement actions.

With yesterday’s net $420 million FCPA enforcement action against Oderbrecht / Braskem, 2016 has also become a record-breaking year in terms of overall corporate FCPA settlement amounts.

Corporate FCPA settlement amounts in 2016 stand at approximately $1.8 billion. (Note: this represents the net number after accounting for various credits and deductions in enforcement actions against foreign companies such as Oderbrecht/Braskem, Embraer, and VimpelCom).

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Rebuttal Points Regarding Lessons From The First Six Months Of The FCPA Pilot Program


Recently Robert Kent (Baker McKenzie) penned this article in Law360 titled “The First 6 Months of FCPA Pilot Program: 10 Lessons.”

This post contains various rebuttal points regarding the article.

First, the article implicitly asserts that the “surge” in FCPA enforcement thus far in 2016 is casually related to announcement of the April 2016 FCPA Pilot Program by the DOJ.

Yes, 2016 has been a record-breaking year for FCPA enforcement as highlighted in this post.

However, the enforcement activity is not casually related to the Pilot Program.

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