FCPA Year In Review: 2014

The biggest Foreign Corrupt Practices Act ("FCPA") story of 2014 was that the cost of resolving an FCPA enforcement action has gone up. In a year in which the number of enforcement actions declined by one, the Department of Justice ("DOJ") and the Securities and Exchange Commission ("SEC") collected $1.57 billion in FCPA penalties and disgorgement, which more than doubled the $720 million collected last year. This significant increase was driven by the resolution of four long-running, high-profile FCPA investigations, each of which involved penalties and disgorgements exceeding $100 million: Alstom, Alcoa, Avon, and Hewlett-Packard. Alstom's $772 million fine was the largest criminal FCPA resolution in U.S. history and was heralded by the DOJ as an example of how the U.S. government will punish companies that break the law and do not adequately cooperate with government investigations into their misconduct. Independent compliance monitors were also required in two of