So far in 2018, 15 companies have disclosed new FCPA-related investigations. That means the pace of disclosure has slowed from the past couple of years.
In 2017, 49 companies disclosed new corruption investigations.
In 2016, 45 companies made new disclosures.
Are the pace of disclosures related to the pace of enforcement activity? Apparently not.
In 2017, just 11 companies resolved FCPA cases with the DOJ or SEC or both, paying about $1.92 billion for the settlements.
In 2016 — the biggest enforcement year in FCPA history — 27 companies paid about $2.48 billion to resolve FCPA cases.
Not all companies disclose FCPA investigations when the investigations begin.
For example, two of the companies that first disclosed FCPA investigations this year have also resolved their cases.
Credit Suisse Group AG first disclosed its FCPA investigation in February 2018 and resolved the case in July.
Research for this post was conducted on FCPA Tracker.
Richard L. Cassin is the publisher and editor of the FCPA Blog.