The Origins Of 2025 Corporate Enforcement Actions
This recent post compared corporate FCPA enforcement actions in 2025 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 three corporate enforcement actions in 2025. (See here for a similar post for 2024; here for 2023; here for 2022; here for 2021; here for 2020; here for 2019, here for 2018, here for 2017, and here for 2016).
The Origins Of 2024 Corporate Enforcement Actions
This recent post compared corporate FCPA enforcement actions in 2024 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 eleven corporate enforcement actions in 2024. (See here for a similar post highlighting the origins of 2023 corporate enforcement actions; here for 2022; here for 2021; here for 2020; here for 2019, here for 2018, here for 2017, and here for 2016).
In summary, of the eleven corporate enforcement actions from 2024, four enforcement actions (36%) originated with a voluntary disclosure (albeit in two instances the DOJ found the disclosures to be imperfect).
Issues To Consider From The RTX Enforcement Action
This prior post went in-depth into the recent RTX (Raytheon) FCPA enforcement action regarding bribery schemes in Qatar.
The net $361.2 FCPA enforcement action involved a net $259.7 million DOJ FCPA enforcement action and a net $101.5 million SEC FCPA enforcement action.
This post highlights additional issues to consider.
Timeline
As RTX previously disclosed:
A Most Interesting Origin
All Foreign Corrupt Practices Act enforcement actions have a point of origin – facts or circumstances which cause law enforcement to investigate.
This post highlights the origins of 2023 FCPA enforcement actions as well as historical origins.
As highlighted in this recent post, the Department of Justice recently announced an FCPA (and related) enforcement action against various individuals associated with Smartmatic in connection with a bribery scheme in the Philippines related to voting machines and election services.
Among the individuals criminally charged (with money laundering offenses) was Juan Andres Donate Bautista (the former Chairman of the Commission on Elections (COMELEC) in the Philippines). The DOJ actually criminally charged Bautista with money laundering offenses in September 2023 and the criminal complaint describes a most interesting origin.
The Origins Of 2023 Corporate Enforcement Actions
This recent post compared corporate FCPA enforcement actions in 2023 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 fourteen corporate enforcement actions in 2023. (See here for a similar post highlighting the origins of 2022 corporate enforcement actions; here for 2021; here for 2020; here for 2019, here for 2018, here for 2017, and here for 2016).
In summary, of the fourteen corporate enforcement actions from 2023, eight enforcement actions (57%) originated with a voluntary disclosure.