This recent post focused on SEC individual FCPA actions in 2020 and historically. Today’s post highlights various facts and figures regarding the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act offenses in 2020 and historically.
The key word above is FCPA offenses.
Some in the FCPA space include enforcement actions containing non-FCPA charges (often money laundering charges against alleged “foreign officials”) related to an FCPA enforcement action as an individual FCPA enforcement action. While it is fine to track such enforcement actions, calling them FCPA enforcement actions is factually false.
Compared to corporate FCPA enforcement actions, tracking individual FCPA enforcement actions is often more difficult because the DOJ does not publicly announce every individual enforcement action and/or certain matters are filed under seal.