In 2019, the overall number of corporate enforcement actions was
slightly higher than in 2018, with twenty-five actions brought,
compared to twenty-four in 2018. The number of individuals charged,
using our parameters, increased markedly, with forty individuals
charged or indictments unsealed in 2019 and two major jury verdicts
in trials in long-running cases, United States v. Hoskins and
United States v. Lambert. The cases in 2019 tended to be
highly concentrated, with thirteen corporations accounting for all
of the corporate enforcement actions, and individual enforcement
actions concentrated in the PetroEcuador, Corpoelec, and PdVSA
bribery schemes. Total corporate penalties this year nearly equaled
the previous year—totaling $2.904 billion in 2019 and $2.908
billion in 2018. Over $1 billion of the 2019 penalties are related
to the late-year enforcement action against Telefonaktiebolaget LM
Ericsson, which represents one of the largest FCPA enforcement
actions in
