Foreign Corrupt Practices Act enforcement, it’s not just about the DOJ.
Granted, as a civil enforcement agency the SEC’s sticks are less sharp than the DOJ’s, but the SEC also claims a meaningful piece of the FCPA enforcement pie (query whether it should – but that is a subject for another day – for instance as discussed in “The Story of the Foreign Corrupt Practices Act” the SEC wanted no part in enforcing the FCPA’s anti-bribery provisions and in recent years an SEC Commissioner stated that anti-corruption policy is not within the SEC’s area of expertise nor further to the SEC’s mission – see here).
This post highlights various facts and figures relevant to SEC corporate FCPA enforcement in 2025.
In short, there are none as there was no corporate FCPA enforcement by the SEC in 2025.
Nevertheless, this post provides some context as well as certain historical data.
[See here for a similar post for 2024; here for 2023; here 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].
In terms of context, there tends to be “less” enforcement during the first year of a Presidential administration as 2025 was. This is demonstrated by the below data for 2017 (first year of the first Trump administration) and 2021 (first year of the Biden administration).
In addition, in 2025 there was an approximate 40 day government shutdown impacting SEC enforcement.
Finally, and often ignored, the SEC does not have jurisdiction over many companies – relatively speaking – only so-called “issuers” (FCPA speak for publicly traded companies or those with reporting obligations to the SEC).
As highlighted in this recent post, the number of “issuers” has significantly declined over the last twenty years (approximately 4,700 exchange-listed companies now compared to a high point of approximately 7,800 in 2007).
Settlement Amounts and Specifics
- in 2025 the SEC collected $0 in 0 corporate enforcement actions;
- in 2024 the SEC collected approximately $185 million in 6 corporate enforcement actions;
- in 2023 the SEC collected approximately $268 million in 9 corporate enforcement actions;
- in 2022 the SEC collected approximately $272 million in 7 corporate enforcement actions;
- in 2021 the SEC collected approximately $171 million in 4 corporate enforcement actions;
- in 2020 the SEC collected approximately $683 million in 8 corporate enforcement actions;
- in 2019 the SEC collected approximately $1.03 billion in 13 corporate enforcement actions;
- in 2018 the SEC collected approximately $382 million in 14 corporate FCPA enforcement actions;
- in 2017 the SEC collected approximately $289 million in 7 corporate FCPA enforcement actions;
- in 2016 the SEC collected approximately $1.07 billion in 24 corporate FCPA enforcement actions;
- in 2015 the SEC collected approximately $114.8 million in 9 corporate FCPA enforcement actions;
- in 2014 the SEC collected approximately $327 million in 7 corporate FCPA enforcement actions;
- in 2013 the SEC collected approximately $300 million in 8 corporate enforcement actions;
- in 2012 the SEC collected approximately $118 million in 8 corporate FCPA enforcement actions;
- in 2011 the SEC collected approximately $148 million in 13 corporate FCPA enforcement actions;
- in 2010 the SEC collected approximately $530 million in 19 corporate FCPA enforcement actions.
