This post provides a summary of Foreign Corrupt Practices Act enforcement activity and related developments from the first quarter of 2019. Although three quarters remain in 2019, FCPA enforcement this year is already the 5th largest in FCPA history (from a settlement amount perspective – $1.11 billion) (see here).
DOJ Enforcement (Corporate)
The DOJ brought three corporate FCPA enforcement action in the first quarter. DOJ actual recovery in these actions was approximately $835 million.