In The Words Of The DOJ
The DOJ recently released its Fraud Section Year in Review.
Among the Fraud Section’s four “litigating units” is the FCPA Unit described as follows.
“The Foreign Corrupt Practices Act (FCPA) Unit is responsible for investigating and prosecuting violations of the FCPA and the Foreign Extortion Prevention Act (FEPA). The FCPA Unit brings criminal enforcement against individuals and companies and focuses its enforcement efforts on both the supply and demand side of corrupt transactions. The FCPA Unit works closely with domestic and foreign partners to advance common efforts in curbing foreign bribery and corruption.”
A Focus On DOJ Individual FCPA Enforcement Actions
This recent post focused on SEC individual FCPA actions in 2025 and historically.
Today’s post highlights various facts and figures regarding the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act offenses in 2025 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 these FCPA enforcement actions is not accurate. (In fact, as highlighted in this prior post, a high percentage of enforcement actions in recent years on the DOJ’s FCPA website are not actual FCPA enforcement actions).
A Focus On SEC Individual Actions
This previous post highlighted various facts and figures from 2025 SEC FCPA enforcement actions against issuers (there was none) as well as historical figures.
This post focuses on SEC FCPA individual actions – both in 2025 and historically.
There were no SEC individual FCPA enforcement actions against individuals in 2025.
However, as highlighted below, 2025 was hardly unique as there was just 2 individual SEC FCPA enforcement against individuals in 2024 and this was preceded by a 4 year gap in SEC individual FCPA enforcement actions.
DOJ FCPA Enforcement – 2025 Year In Review
This recent post summarized SEC Foreign Corrupt Practices Act enforcement against issuers in 2025.
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 2025 against business organizations. (See here for a similar post for 2024; here for 2023; here for for 2022; here for 2021; here for 2020; here for 2019; here for 2018; here for 2017, here for 2016, here for 2015, here for 2014, here for 2013, here for 2012, here for 2011, and here for 2010).
SEC FCPA Enforcement – 2025 Year In Review
Foreign Corrupt Practices Act enforcement, it’s not just about the DOJ.
Granted, as a civil enforcement agency the SEC’s sticks are less sharp than the DOJ’s, but the SEC also claims a meaningful piece of the FCPA enforcement pie (query whether it should – but that is a subject for another day – for instance as discussed in “The Story of the Foreign Corrupt Practices Act” the SEC wanted no part in enforcing the FCPA’s anti-bribery provisions and in recent years an SEC Commissioner stated that anti-corruption policy is not within the SEC’s area of expertise nor further to the SEC’s mission – see here).
This post highlights various facts and figures relevant to SEC corporate FCPA enforcement in 2025.
In short, there are none as there was no corporate FCPA enforcement by the SEC in 2025.
Nevertheless, this post provides some context as well as certain historical data.