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 2024 FCPA enforcement statistics as well as comparisons to historical statistics. If you missed the daily
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U.S. Transfers $53 Million In Forfeited Corruption Proceeds To Nigeria
Efforts by the U.S. government to combat foreign corruption are broader than just the Foreign Corrupt Practices Act. For instance, in 2009 the DOJ announced a Kleptocracy Asset Recovery Initiative.
As described by the DOJ, the “Kleptocracy Asset Recovery Initiative is led by a team of dedicated prosecutors in the Criminal Division’s Money Laundering and…
A Focus On DOJ Individual Actions
This recent post focused on SEC individual FCPA actions in 2024 and historically.
Today’s post highlights various facts and figures regarding the DOJ’s prosecution of individuals for Foreign Corrupt Practices Act offenses in 2024 and historically.
The key word above is FCPA offenses.
Some in the FCPA space include enforcement actions containing non-FCPA charges (often money…
DOJ FCPA Enforcement – 2024 Year In Review
This recent post summarized SEC Foreign Corrupt Practices Act enforcement against issuers in 2024.
Today’s post focuses on the other FCPA enforcement agency – the Department of Justice – and highlights various facts and figures relevant to DOJ FCPA enforcement in 2024 against business organizations. (See here for a similar post for 2023; here for…
FCPA Enforcement Actions Against Foreign Companies From OECD Convention Peer Countries
As highlighted in this post, like prior years (see here, here, here, here, here, here, here and here) much of the largeness of 2024 FCPA enforcement resulted from corporate enforcement actions against foreign companies.
Specifically, of the 11 corporate Foreign Corrupt Practices Act enforcement actions in 2024, 5…
A Focus On SEC Individual Actions
This previous post highlighted various facts and figures from 2024 SEC FCPA enforcement actions against issuers.
This post focuses on SEC FCPA individual actions – both in 2024 and historically.
Like the DOJ, the SEC frequently speaks in lofty rhetoric concerning its focus on holding individuals accountable under the FCPA or other laws.
Set forth…
SEC FCPA Enforcement – 2024 Year In Review
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 significant piece of the FCPA enforcement pie (query whether it should – but that is a subject for another day – for instance…
The “Foreign Officials” Of 2024
A “foreign official.”
Without one, there can be no FCPA anti-bribery violation (civil or criminal). Who were the alleged “foreign officials” of 2024?
This post highlights the alleged “foreign officials” from 2024 corporate DOJ and SEC FCPA enforcement actions.
As is apparent from the descriptions below, in certain instances the enforcement agencies describe the “foreign…
Like Prior Years, The Gray Cloud Of FCPA Scrutiny Lasted Too Long In 2024
This recent post highlighted the origins of corporate Foreign Corrupt Practices Act enforcement actions in 2024.
Continuing with the 2024 FCPA statistical feast, this post follows the chronology of scrutiny to enforcement and highlights one of the most troubling policy issues when it comes to FCPA enforcement.
That is – FCPA scrutiny simply lasts too…
The Origins Of 2024 Corporate Enforcement Actions
This recent post compared corporate FCPA enforcement actions in 2024 to prior years.
However, before a Foreign Corrupt Practices Act enforcement action is announced, scrutiny must first arise.
This post highlights the origins of the eleven corporate enforcement actions in 2024. (See here for a similar post highlighting the origins of 2023 corporate enforcement actions;…