Foreign Corrupt Practices Act investigations were down significantly last year, with the U.S. Department of Justice settling with only two companies and collecting just $24.2 million, according to a new report by Jones Day. That figure represents a drastic drop from 2014, when the DOJ collected more than $1.25 billion from 10 corporate enforcement actions. “Not since 2004 has the DOJ’s corporate FCPA prosecution effort resulted in so few cases,” according to report authors.
So what happened? The DOJ explains the off year as a result of fewer self-disclosures by companies, as well as its focus on pursuing what it calls “higher-impact” bribery cases. The DOJ says that amid the slowdown, it has tripled the number of FBI agents investigating foreign bribery and plans to double the amount of prosecutors on FCPA investigations. The report authors note these additional resources will likely lead to more enforcement, but aren’t sure whether results will be seen this year or next.
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