This post, the first in a weeks-long year in review statistical feast on FCPA Professor, compares corporate FCPA enforcement in 2022 to prior years.
Keep the numbers in this post in mind when you see other 2022 FCPA enforcement statistics that use creative and haphazard counting methods or fail to use accurate or consistent math. (See here).
The most reliable and accurate way to keep FCPA enforcement statistics is by using the “core” approach which focuses on unique instances of FCPA scrutiny. The core approach does not distort FCPA enforcement statistics by double counting parallel DOJ and SEC actions involving the same core conduct announced on the same day nor does the core approach distort FCPA enforcement statistics by separately counting the sometimes unique ways the DOJ slices and dices corporate conduct between parent companies and subsidiaries.