This recent post compared corporate FCPA enforcement actions in 2020 to prior years. However, before a Foreign Corrupt Practices Act enforcement action is announced, scrutiny must first arise.

This post highlights the origins of the 12 core corporate enforcement actions in 2020. (See here for a similar post highlighting the origins of 2019 corporate enforcement actions; here for 2018 corporate enforcement actions; here for 2017 corporate enforcement actions and here for 2016 corporate enforcement actions).

As highlighted in the post, like prior years, 2020 corporate enforcement actions originated in a variety of ways from voluntary disclosures, to pro-active government investigations, to foreign law enforcement investigations.

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This post, the first in a weeks-long statistical feast on FCPA Professor, compares corporate FCPA enforcement in 2020 to prior years. As reflected in the post, measured in terms of actual settlement amounts, 2020 was the largest in FCPA history as the DOJ/SEC collected approximately $2.78 billion (eclipsing the approximately $2.65 billion collected in 2019) in corporate enforcement actions.

Keep the numbers in this post in mind when you see other 2020 FCPA enforcement statistics that use creative and haphazard counting methods or fail to use accurate or consistent math. (See here for instance – ridiculously asserting that the DOJ/SEC “imposed financial penalties totaling a record $6.4 billion” in 2020).

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