INTRODUCTION: RECENT TRENDS AND PATTERNS IN FCPA ENFORCEMENT -

Although FCPA enforcement across the 2018 calendar year seemed to ebb and flow, in retrospect the enforcement agencies brought a typical number of enforcement actions, which in the aggregate resulted in the second-highest penalty total in one year. That being said, the vast majority of FCPA enforcement actions brought in 2018 were small, and the SEC was significantly more active than the DOJ. Indeed, other than a very active summer, the DOJ only brought one corporate enforcement action during the rest of the calendar year. Still, several of the DOJ’s handful of enforcement actions were notable, including the largest penalty imposed as part of an FCPA enforcement action.