Recent Trends And Patterns In Foreign Corrupt Practices Act Enforcement

In January 2017, we published our bi-annual Recent Trends and Patterns in FCPA Enforcement report, part of our FCPA Digest, which provides an analysis of recent enforcement trends and patterns in the United States, the UK and elsewhere, as well as guidance on emerging best practices in FCPA and global anti-corruption compliance programs.

2016 was a banner year for FCPA enforcement. The DOJ and SEC's combined 27 corporate enforcement actions and $6 billion in total corporate sanctions (due in large part to the sanctions levied against Odebrecht) are the highest since the statute's enactment. However, while the 2016 enforcement year has seen a series of blockbuster FCPA enforcement actions, by and large the remainder of the 2016 FCPA cases have involved relatively small-to-medium-sized penalties over relatively run-of-the-mill bribery schemes. Among the highlights from 2016 were: