Foreign Corrupt Practices Act (FCPA) enforcement activity reached new heights in 2019. Corporate penalties paid to US enforcement agencies topped last year’s record levels, and individuals were charged at a pace matching last year’s near-record level.2 As discussed in detail below, Latin American citizens from Ecuador to Venezuela have recently found themselves facing criminal anti-corruption charges in federal courts in the US.

These trends are critically important both to Latin American companies and to US companies doing business in Latin America. As recent enforcement trends show, foreign companies are a perennial target of US enforcement agencies. Nine of the top 10 all-time largest FCPA enforcement actions have been brought against companies based outside the US, including several Brazilian companies.