The SEC’s most recent Foreign Corrupt Practices Act enforcement action was against Gol Airlines – a Brazil corporation (see here for the prior post).
Prior to that, was the SEC’s FCPA enforcement action against Tenaris – a Luxembourg corporation (see here and here for prior posts). Prior to that, was the SEC’s FCPA enforcement against KT Corp. – a South Korean corporation (see here and here for prior posts). Prior to 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, against Amec Foster Wheeler – a U.K. corporation and successor in interest to a Swiss corporation (see here). Prior to that, against Deutsche Bank – a German corporation (see here and here).
The only SEC FCPA enforcement actions in the last approximate two years against U.S. companies have been against Stericycle (see here and here for prior posts) and Goldman Sachs (see here and here for prior posts).
