Foreign Corrupt Practices Act (FCPA) enforcement activity in
2013 was robust, with DOJ and the SEC bringing 31 new FCPA
enforcement actions, exceeding 2012's total of 25. Total
penalties amounted to more than $720 million, the second highest
year on record.
Many trends from earlier years continued in 2013. International
cooperation among law enforcement authorities remained strong. For
example, 2013 saw the first coordinated enforcement action between
U.S. and French authorities in a major foreign bribery case
(U.S. v. Total S.A.). DOJ also continued to make good on
its promise to prosecute individuals, bringing or announcing 14
actions against individuals in 2013. And, DOJ and the SEC seemed to
continue their willingness to reward companies for their swift
voluntary disclosure and ongoing cooperation, although the extent
of that reward has been the subject of much debate.
