An FCPA Statistical Feast

January 22, 2024

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 2023 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 2023 corporate FCPA enforcement to prior years.

This post highlights the origins of 2023 corporate FCPA enforcement actions.

This post highlights how the gray cloud of FCPA scrutiny lasted too long in 2023. Specifically, 5 years was the approximate median length of time companies that resolved FCPA enforcement actions in 2023 were under scrutiny.

This post focuses specifically on DOJ FCPA enforcement in 2023 and contains a number of statistics including comparisons to historical norms.

This post highlights DOJ FCPA enforcement actions against individuals in 2023 and how approximately 75% of corporate FCPA enforcement actions over the past 15 years have not resulted in any DOJ FCPA charges against company employees.

This post takes a closer look at DOJ FCPA enforcement actions against individuals and the strange public – private divide. In other words, even though most corporate FCPA enforcement are against issuers, most individual actions are against individuals associated with non-issuers.

This post focuses specifically on SEC FCPA enforcement in 2023 and contains a number of statistics including comparisons to historical statistics.

This post highlights SEC FCPA enforcement actions against individuals in 2023 (there were none) and how the time gap between individual enforcement actions is approaching 3.5 years.

This post highlights the alleged “foreign officials” from 2023 corporate enforcement actions.

This post highlights how much of the largeness of 2023 corporate enforcement was a result of enforcement actions against foreign companies from OECD Convention countries and poses the question: should the U.S. back off of such prosecutions?