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Record-Breaking: There Have Been More Corporate FCPA Enforcement Actions In 2016 Than Any Prior Year In FCPA History

record breaker

Last week was an active week in Foreign Corrupt Practices Act enforcement as the SEC fiscal year came to a close.

A full three months remain in 2016 FCPA enforcement.

However, 2016 is already a record-breaking year

There have been more corporate enforcement actions in 2016 than any prior year in FCPA history.

Listed below are the 22 corporate enforcement actions thus far in 2016.

  • GSK
  • NCH Corp.*
  • HMT LLC*
  • Och-Ziff
  • AB InBev
  • Nu-Skin
  • Key Energy
  • AstraZeneca
  • Johnson Controls
  • LAN Airlines
  • Nortek
  • Akamai Technologies
  • Analogic
  • Las Vegas Sands
  • Qualcomm
  • Olympus Latin America
  • Nordion
  • Novartis
  • VimpelCom
  • PTC
  • SciClone Pharmaceuticals
  • SAP

*disgorgement paid pursuant to a DOJ “declination letter”

The previous record for corporate enforcement actions was 21 in 2010.

Although 2016 has set a record for the number of corporate enforcement actions, it has not yet set a record for the largest total corporate settlement amounts in a given year.

Thus far, 2016 total corporate settlement amounts stand at approximately $1 billion (with approximately $810 million in two enforcement actions: Och Ziff and VimpelCom).

In 2010, total corporate settlement amounts were approximately $1.4 billion and in 2014 total corporate settlement amounts were approximately $1.6 billion.

For methodology, see “A Common Language to Remedy Distorted FCPA Enforcement Statistics.”

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