DOJ FCPA Enforcement – 2025 Year In Review

January 15, 2026

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).

Settlement Numbers and Amounts

In 2025, the DOJ brought 3 corporate enforcement actions.

By comparison:

in 2024 the DOJ brought 9 corporate enforcement actions;
in 2023 the DOJ brought 7 corporate enforcement actions;
in 2022 the DOJ brought 7 corporate enforcement actions;
in 2021 the DOJ brought 2 corporate enforcement actions;
in 2020 the DOJ brought 8 corporate enforcement actions;
in 2019 the DOJ brought 8 corporate enforcement actions;
in 2018 the DOJ brought 8 corporate enforcement actions;
in 2017 the DOJ brought 9 corporate enforcement actions;
in 2016 the DOJ brought 13 corporate enforcement actions;
in 2015 the DOJ brought 2 corporate enforcement actions;
in 2014 the DOJ brought 7 corporate enforcement actions;
in 2013 the DOJ brought 7 corporate enforcement actions;
in 2012 the DOJ brought 9 corporate enforcement actions;
in 2011 the DOJ brought 11 corporate enforcement actions;
in 2010 the DOJ brought 17 corporate enforcement actions.

(Note: these figures use the “core” approach to FCPA statistics – see here for the prior post – an approach also endorsed by the DOJ – see here).

In the 3 corporate FCPA enforcement actions from 2025, the DOJ collected approximately $123 million.

By comparison:

in the 9 corporate FCPA enforcement actions from 2024, the DOJ collected approximately $1.09 billion.
in the 7 corporate enforcement actions from 2023, the DOJ collected approximately $252 million;
in the 7 corporate enforcement actions from 2022, the DOJ collected approximately $652 million;
in the 2 corporate enforcement actions from 2021, the DOJ collected approximately $87.2 million;
in the 8 corporate enforcement actions from 2020, the DOJ collected approximately $2.10 billion;
in the 8 corporate enforcement actions from 2019, the DOJ collected approximately $1.62 billion;
in the 8 corporate enforcement actions from 2018, the DOJ collected approximately $618 million;
in the 8 corporate enforcement actions from 2017, the DOJ collected approximately $845 million;
in the 13 corporate enforcement actions from 2016, the DOJ collected approximately $1.17 billion;
in the 2 corporate enforcement actions from 2015, the DOJ collected approximately $24.2 million;
in the 7 corporate enforcement actions from 2014, the DOJ collected approximately $1.25 billion;
in the 7 corporate enforcement actions from 2013, the DOJ collected approximately $420 million;
in the 9 corporate enforcement actions from 2012, the DOJ collected approximately $142 million;
in the 11 corporate enforcement actions from 2011, the DOJ collected approximately $355 million;
in the 17 corporate enforcement actions from 2010, the DOJ collected approximately $870 million;

Corporate v. Individual Prosecutions

In the 3 corporate DOJ enforcement actions in 2025, 1 (33%) has resulted, at present, in any related DOJ FCPA charges.

Stay tuned for future posts specifically about DOJ individual FCPA enforcement actions in 2025 and historically.

Resolution Vehicles

The 3 corporate FCPA enforcement actions by the DOJ in 2025 involved: 1 so-called declination with disgorgement; 1 deferred prosecution agreement; and 1 indictment. Thus, 66% of DOJ corporate FCPA enforcement in 2025 involved an alternative resolution vehicle not subjected to any meaningful judicial scrutiny.

By comparison:

in 2024, 78% of DOJ corporate FCPA enforcement involved alternative resolution vehicles;
in 2023, 100% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2022, 86% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2021, 100% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2020, 75% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2019, 100% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2018, 100% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2017, 100% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2016 92% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2015 100% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2014 71% of DOJ corporate enforcement actions involved alternative resolution vehicles;
in 2013, 100% of corporate DOJ enforcement actions involved alternative resolution vehicles;
in 2012 100% of corporate DOJ enforcement actions involved alternative resolution vehicles;
in 2011 82% of corporate DOJ enforcement actions involved alternative resolution vehicles;
in 2010 94% of corporate DOJ enforcement actions involved alternative resolution vehicles.

Voluntary Disclosures

Of the 3 DOJ corporate enforcement actions in 2025, 2 (66%) were the result of a voluntary disclosure.

By comparison:

in 2024, 33% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2023, 43% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2022, 43% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2021, 0% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2020, 13% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2019, 37% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2018 25% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2017 33% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2016 38% of DOJ corporate enforcement actions were the result of a voluntary disclosure;
in 2015, 50% of corporate FCPA enforcement actions were the result of a voluntary disclosure;
in 2014, 29% of corporate FCPA enforcement actions were the result of a voluntary disclosures;
in 2013, 57% of corporate FCPA enforcement actions were the result of a voluntary disclosure or the direct result of a related voluntary disclosure;
in 2012, 78% of corporate FCPA enforcement actions were the result of a voluntary disclosure or casually related to previous voluntary disclosures;
in 2011, 73% of corporate FCPA enforcement actions were the result of corporate voluntary disclosures.

Monitors

Of the 3 corporate FCPA enforcement actions in 2025, 0 (0%) resulted in a formal corporate monitor imposed by the DOJ. (Note: the Smartmatic enforcement action remains active after the company was indicted).

By way of comparison:

in 2024, 11% of corporate enforcement actions resulted in a formal corporate monitor;
in 2023, 0% of corporate enforcement actions resulted in a formal corporate monitor;
in 2022, 29% of corporate enforcement actions resulted in a formal corporate monitor;
in 2021 0% of corporate enforcement actions resulted in a formal corporate monitor;
in 2020 0% of corporate enforcement actions resulted in a formal corporate monitor;
in 2019 50% of corporate enforcement actions resulted in a formal corporate monitor;
in 2018 12% of corporate enforcement actions resulted in a formal corporate monitor;
in 2017 33% of corporate enforcement actions resulted in a formal corporate monitor;
in 2016 54% of corporate enforcement actions resulted in a formal corporate monitor;
in 2015 50% of corporate enforcement actions resulted in a formal corporate monitor;
in 2014 14% of corporate enforcement actions resulted in a formal corporate monitor;
in 2013 57% of corporate enforcement actions resulted in a formal corporate monitor;
in 2012 33% of corporate enforcement actions resulted in a formal corporate monitor;
in 2011 9% of corporate enforcement actions resulted in a formal corporate monitor; and
in 2010 41% of corporate enforcement actions resulted in a formal corporate monitor.

This remainder of this post provides an overview of corporate DOJ FCPA enforcement in 2025.

Liberty Mutual (Aug. 7)

See here and here for prior posts.

Charges: N/A – declination with disgorgement letter refers to violations of the FCPA’s anti-bribery provisions.

Resolution Vehicle: Declination with Disgorgement

Guidelines Range: Not mentioned in the Declination with Disgorgement Letter

Settlement: $4.7 million

Origin: Voluntary disclosure

Monitor: No

Individuals Charged: No

Smartmatic (Oct 16)

See here for a prior post.

Charges: Criminal indictment charging conspiracy to violate the FCPA’s anti-bribery provisions, money laundering conspiracy, and money laundering.

Resolution Vehicle: N/A

Guidelines Range: N/A

Settlement: N/A

Origin: The corporate enforcement action is based on the same core allegations of a 2024 enforcement action against individuals associated with Smartmatic.

Monitor: N/A

Individuals Charged: Yes

Millicom / Comcel (Nov 10)

See here and here for prior posts.

Charges: Conspiracy to violate the FCPA’s anti-bribery provisions.

Resolution Vehicle: Criminal information resolved through a deferred prosecution agreement.

Guidelines Range: $120 – $240 million.

Settlement: $118.2 million.

Origin: As stated by the DOJ: “in 2015, Millicom voluntarily and timely disclosed to the Criminal Division misconduct at the Company (Millicom’s then-joint venture) that, in part, forms the basis for this Agreement. However, despite Millicom’s 55% ownership share, Millicom lacked operational control over the Company. The Company’s Guatemalan shareholder used its operational control to prevent Millicom from accessing critical information, and to prevent Millicom from requiring Company personnel to cooperate with the Fraud Section’s investigation and take remedial actions. The Fraud Section closed its initial investigation in 2018. Two years later, in 2020, the Offices obtained and proactively developed new evidence from sources other than the Company and Millicom regarding the Company’s conduct and reopened their investigation on that basis. During the second phase of the investigation, the Offices obtained new and additional evidence about the scope of the Company’s conduct, including that the criminal conduct continued during and after the Offices’ closure of the first phase of the investigation and involved narcotrafficking proceeds that were used to generate cash for some of the bribe payments.

Monitor: No

Individuals Charged: No.