As highlighted in this post, like prior years (see here) much of the largeness of 2017 FCPA enforcement resulted from corporate enforcement actions against foreign companies.
Specifically, of the 13 corporate enforcement actions from 2017, 5 (approximately 40%) were against foreign companies (based in many instances on mere listing of securities on U.S. markets and in a few instances on sparse allegations of a U.S. nexus in furtherance of an alleged bribery scheme). Even more dramatic, of the net $1.13 billion FCPA settlement amounts from 2017 corporate enforcement actions, approximately 90% of this number was from enforcement actions against foreign companies.
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