Historically, the third and fourth quarters are active in terms of Foreign Corrupt Practices Act enforcement and it is a near certainty that there will be more FCPA enforcement this year.
Nevertheless, with 4.5 months left in the year, as highlighted below 2019 is already the third largest in FCPA history in terms of settlement amounts.
| Year | Core Corporate Enforcement Actions
|
Net FCPA Settlement Amounts |
| 2019 | 7 | $1.5 billion |
| 2018 | 17 | $1 billion |
| 2017 | 13 | $1.1 billion |
| 2016 | 27 | $2.4 billion |
| 2015 | 11 | $139 million |
| 2014 | 10 | $1.6 billion |
| 2013 | 9 | $720 million |
| 2012 | 12 | $260 million |
| 2011 | 16 | $503 million |
| 2010 | 21 | $1.4 billion |
| 2009 | 11 | $645 million |
| 2008 | 10 | $885 million |
| 2007 | 15 | $149 million |
Of course, just a few 2019 FCPA enforcement actions (MTS – $850 million, Walmart – $283 million, and Fresenius and $232 million) are driving the net settlement numbers, but this same dynamic is present in most other years as well.
