2018 FCPA Enforcement Actions And Highlights

Overall, 2018 was a more active year in terms of Foreign Corrupt Practices Act ("FCPA") enforcement actions compared to 2017. In 2018, the Department of Justice ("DOJ") took a total of 40 enforcement actions,¹ and the Securities and Exchange Commission² ("SEC") took a total of 14 enforcement actions.

According to the FCPA Blog's 2018 FCPA Enforcement Index, 16 companies paid a total of $2.89 billion to resolve FCPA cases in 2018, including resolutions with the DOJ and the SEC, as well as DOJ declinations with disgorgement.³ As anticipated over the past few years, the Yates Memo might have arguably shown its effect, as 32 out of the 40 enforcement actions taken by the DOJ were related to real persons, most of which were related to multiple bribery schemes involving PDVSA, a Venezuelan state-owned oil and natural gas company. In terms of the sectoral concentration of FCPA enforcement actions in 2018, we observe that a wide array of sectors were affected by these