Foreign Corrupt Practices Act 2015 Year-End Update

Both the United States Department of Justice (DOJ) and the United States Securities and Exchange Commission (SEC) have continued their focus on anticorruption enforcement in 2015. Although there was a decline in enforcement actions by both DOJ and the SEC under the Foreign Corrupt Practices Act (FCPA) from 2014, recent actions and announcements have made it clear that FCPA enforcement will remain a priority in 2016. Over the course of 2015, the DOJ and the SEC initiated a total of 12 corporate enforcement actions, with the SEC responsible for 10 of the 12.

The DOJ entered into two corporate FCPA resolutions in 2015: a non-prosecution agreement with Florida-based IAP Worldwide Services and a deferred-prosecution agreement with New Jersey-based Louis Berger International. These two resolutions involved approximately $24 million in penalties. As for individual enforcement actions, the SEC and DOJ have pursued FCPA charges in seven different enforcement actions. This is