Searching For The Supposed “Lull In Enforcement”

Reading the FCPA Blog is often like reading the Onion.

At first you think you are reading a legitimate news item but realize its satire, but you keep on reading for the entertainment value.

For instance this recent FCPA Blog post about “what happened at this year’s SCCE Compliance and Ethics Institute in Chicago” earlier this month states:

“The Lull in Enforcement

Around the water cooler, many folks at the conference expressed concerns about the lull in FCPA enforcement. The common theme was that it is harder to justify compliance budgets when the perceived threat of mega-enforcements is reduced. Deputy AG Monaco, responding to a question after her speech, addressed the lull, saying that there is a strong enforcement pipeline coming. I heard a number of attendees say they are waiting for this to materialize.”

From where does this utter nonsense originate (other than perhaps the FCPA Blog itself)?

“Lull in enforcement”? Compared to what?

As highlighted below, and with over two months remaining in 2023 FCPA enforcement (including year end which historically is a robust time period for enforcement), corporate FCPA enforcement in 2023 is at or has exceeded corporate enforcement actions in seven recent prior years and is at the median for corporate enforcement actions per year over the past 15 years.

Corporate FCPA Enforcement Actions (2008 – 2023 YTD)