Prior to the that, was the SEC’s FCPA enforcement action against Credit Suisse – a Swiss Corporation (see here). Prior to that against WPP – a United Kingdom Corporation (see here). Prior to that Amec Foster Wheeler – a U.K. corporation and successor in interest to a Swiss corporation (see here). Prior to that Deutsche Bank – a German corporation (see here and here). In fact, all of the SEC’s corporate FCPA enforcement actions in 2021 were against foreign corporations.
If you are scoring at home, that’s five straight SEC corporate FCPA enforcement involving foreign companies.