FCPA Digest - Recent Trends and Patterns in the Enforcement of the Foreign Corrupt Practices Act - June 2023

In 2022, the DOJ and the SEC resolved a total of ten corporate enforcement actions under the FCPA, more than double the number in the previous year. While the average corporate penalties only slightly increased to $168 million from last year’s $164 million, the total penalties reached $1.68 billion, a notable increase from the prior year’s $658 million. Four out of the ten resolutions were paired enforcement actions, and the largest resolution of the year, Glencore, was a collaboration between the DOJ and the CFTC.

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