This recent post compared corporate FCPA enforcement actions in 2021 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 four core corporate enforcement actions in 2021. (See here for a similar post highlighting the origins of 2020 corporate enforcement actions; here for 2019, here for 2018, here for 2017, and here for 2016).
Compared to prior years, this year in review statistic (like many from 2021) is less than enlightening given the small number of corporate enforcement actions in 2021 coupled with the fact that the specific origin of an enforcement action is often dependent on information contained in a resolution document.