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A Look Back At 2014 FCPA Enforcement And Related Developments

2014 year in review

Each year, in addition to numerous posts published on this site, I author a year a review / recent developments article devoted to the Foreign Corrupt Practices Act and related issues.

The 2014 version is forthcoming in the Santa Clara Journal of International Law and can be downloaded for free here.

Among the issues addressed in the article are the following:

  • A wide variety of FCPA enforcement statistics from 2014;
  • A comparison of enforcement statistics from 2014 to prior years;
  • The wide spectrum of FCPA enforcement actions from 2014 and how the breadth of such allegations send confusing compliance messages to those subject to the FCPA;
  • The wide gap between corporate and individual FCPA enforcement and a relevant data point which helps explain the gap;
  • The surge in SEC administrative actions to resolve alleged instances of FCPA scrutiny and why the surge is problematic;
  • The most important FCPA legal development from 2014; and
  • How judicial scrutiny of enforcement theories related to FCPA enforcement should cause pause as to certain FCPA enforcement theories.

Combine the 2014 year in review article with the ones below and you will have an extensive collection of FCPA statistics, trends, and analysis over time.

For 2013, see here.

For 2012, see here.

For 2011, see here.

For 2010, see here.

For 2009, see here.

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