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In The Words Of The DOJ


Recently the Department of Justice Fraud Section released its 2022 Year in Review.

Set forth below are the FCPA relevant portions.

The Fraud Section has three “litigating units” including the FCPA Unit described as follows:

“The Foreign Corrupt Practices Act (FCPA) Unit has primary jurisdiction to investigate and prosecute violations of the FCPA and works in parallel with the Securities and Exchange Commission (SEC), which has civil enforcement authority for violations of the FCPA by publicly traded companies. The FCPA Unit has brought criminal enforcement actions against individuals and companies and has focused its enforcement efforts on both the supply side and demand side of corrupt transactions. The FCPA Unit has also brought cases in parallel to the Commodity Futures Trading Commission (CFTC) and other agencies. The FCPA Unit also plays a leading role in developing policy as it relates to the FCPA, and training and assisting foreign governments in the global fight against corruption.”

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An FCPA Statistical Feast

Kid in Candy Store

If the Foreign Corrupt Practices Act is an area of your practice or interest, this post may make you feel like a kid in a candy store.

FCPA Professor has been the place to visit this month for in-depth 2022 FCPA enforcement statistics as well as comparisons to historical statistics. If you missed the daily posts, no worries. This post consolidates in one place the statistics recently published on FCPA Professor.

This post compares 2022 corporate FCPA enforcement to prior years.

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DOJ Individual Actions: The Strange Public – Private Divide


These pages track all sorts of Foreign Corrupt Practices Act statistics.

Some of the statistics are “inside baseball” like and other statistics (such as the long time periods associated with FCPA scrutiny or the general lack of individual enforcement actions in connection with most corporate enforcement actions) raise significant public policy issues and/or undermine government rhetoric.

The statistic discussed in this post fits all three categories: it is equal parts “inside baseball,” it raises significant public policy issues, it undermines government rhetoric, and moreover it is just plain strange.

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A Focus On DOJ Individual FCPA Enforcement Actions


This recent post focused on SEC individual FCPA actions in 2022 and historically.

Today’s post highlights various facts and figures regarding the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act offenses in 2022 and historically.

The key word above is FCPA offenses.

Some in the FCPA space include enforcement actions containing non-FCPA charges (often money laundering charges against alleged “foreign officials” or with increasing frequency money laundering charges against alleged bribe payors – see here) related to an FCPA enforcement action as an individual FCPA enforcement action. While it is fine to track such enforcement actions, calling them FCPA enforcement actions is factually false. (In fact, as highlighted in this prior post, approximately 55% of enforcement actions in recent years on the DOJ’s FCPA website are not actual FCPA enforcement actions).

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DOJ FCPA Enforcement – 2022 Year In Review


This recent post highlighted SEC Foreign Corrupt Practices Act enforcement against issuers in 2022.

Today’s post focuses on the other FCPA enforcement agency – the Department of Justice – and highlights various facts and figures relevant to DOJ FCPA enforcement in 2022 against business organizations. (See here for a similar post from 2021; here for a similar post from 2020; here for a similar post from 2019; here for a similar post from 2018; here from 2017, here from 2016, here from 2015, here from 2014, here from 2013, here from 2012, here from 2011, and here from 2010).

Settlement Numbers and Amounts

In 2022, the DOJ brought 7 corporate enforcement actions.

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