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ARTICLE · 05 FEBRUARY 2016

FCPA 2015 Year In Review

Jones Day
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In 2015, the year after the DOJ resolved several long-term and large-dollar FCPA investigations, the most significant FCPA story was the sharp decrease in both the number and size of the DOJ's corporate FCPA resolutions.

United StatesCriminal Law
Hank Walther
Hank Walther
Theodore Chung
Theodore Chung
Richard Deane Jr.
Richard Deane Jr.
Samir Kaushik
Samir Kaushik
Karen Hewitt
Karen Hewitt
Henry Klehm III
Henry Klehm III
Jerry Ling
Jerry Ling
Joan McKown
Joan McKown
Daniel Reidy
Daniel Reidy
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Introduction

In 2015, the year after the Department of Justice ("DOJ") resolved several long-term and large-dollar Foreign Corrupt Practices Act ("FCPA") investigations, the most significant FCPA story was the sharp decrease in both the number and size of the DOJ's corporate FCPA resolutions. The DOJ settled FCPA cases with only two companies and collected $24.2 million in 2015, figures that equal only a fraction of the ten corporate enforcement actions and over $1.25 billion collected in 2014. Not since 2004 has the DOJ's corporate FCPA prosecution effort resulted in so few cases. The DOJ attributed this drop to fewer self-disclosures and to its focus on pursuing more complicated "higher-impact" bribery cases. Against this slowdown in FCPA enforcement, the DOJ invested in the future of its enforcement regime by tripling the number of Federal Bureau of Investigation ("FBI") agents devoted to investigating foreign bribery cases, hiring a dedicated compliance expert,

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