Today’s post is short, but poses some questions to ponder.
Some are lamenting the lack of corporate FCPA enforcement actions thus far in 2025.
Some are lamenting the reported decline in DOJ FCPA prosecutors from approximately 30 to approximately 15.
Yet lost in these lamentations is often any discussion of the following questions.
How many corporate FCPA enforcement actions should there be each year?
After all, the below graphic highlights where FCPA enforcement currently stands in 2025 compared to prior years.
How many DOJ FCPA prosecutors should there be?
How does 15 DOJ FCPA prosecutors compare to the number of DOJ FCPA prosecutors for approximately 45 of the FCPA’s nearly 50 years?
