In 2019, the overall number of corporate enforcement actions was slightly higher than in 2018, with twenty-five actions brought, compared to twenty-four in 2018. The number of individuals charged, using our parameters, increased markedly, with forty individuals charged or indictments unsealed in 2019 and two major jury verdicts in trials in long-running cases, United States v. Hoskins and United States v. Lambert. The cases in 2019 tended to be highly concentrated, with thirteen corporations accounting for all of the corporate enforcement actions, and individual enforcement actions concentrated in the PetroEcuador, Corpoelec, and PdVSA bribery schemes. Total corporate penalties this year nearly equaled the previous year totaling $2.904 billion in 2019 and $2.908 billion in 2018. Over $1 billion of the 2019 penalties are related to the late-year enforcement action against Telefonaktiebolaget LM Ericsson, which represents one of the largest FCPA enforcement actions in history. Prior to this announcement, the sole outlier in 2019 had been MTS at $850 million. While over half of the year’s penalties were thus attributed to outliers, the average excluding outliers remained fairly high compared to recent years, indicating that the remaining penalties were relatively evenly distributed amongst the other enforcement actions.