As highlighted in this post, like prior years (see here, here, here, here and here) much of the largeness of 2021 FCPA enforcement resulted from corporate enforcement actions against foreign companies.
Specifically, of the four corporate Foreign Corrupt Practices Act enforcement actions in 2021, four (100%) were against foreign companies (based in many instances on mere listing of securities on U.S. markets or in a few instances on sparse allegations of a U.S. nexus in furtherance of a bribery scheme). Of the net approximate $259 million in FCPA settlement amounts from 2021 corporate enforcement actions, $259 million (100%) was from enforcement actions against foreign companies.
Of the net approximate $2.78 billion in FCPA settlement amounts from 2020 corporate enforcement actions, approximately $910.5 million (33%) was from enforcement actions against foreign companies. (Note: the record setting $1.26 billion FCPA enforcement action against U.S. company Goldman Sachs significantly reduced this number from prior years).