This previous post highlighted various facts and figures from 2021 SEC FCPA enforcement actions against issuers.
This post focuses on SEC FCPA individual actions – both in 2021 and historically.
Like the DOJ, the SEC frequently speaks in lofty rhetoric concerning its focus on holding individuals accountable under the FCPA.
As highlighted here, in 2021 the SEC’s Chairman stated: “Accountability — whether individual or institutional — is an important part of the SEC’s enforcement agenda. We’ll use all of the tools in our toolkit to investigate wrongdoing and hold bad actors accountable …”.