Last Wednesday, J&F Investimentos S.A. and a subsidiary agreed to pay a total of $285 million to settle FCPA charges brought by the SEC and DOJ. With that settlement, the Foreign Corrupt Practices Act hit its two biggest milestones yet.
The first milestone: 2020 has officially become the largest year ever for FCPA settlements, with resolutions worth $2.94 billion. Falling to second place is 2019, with total settlements valued at $2.9 billion.
So far in 2020, there have been nine FCPA corporate settlements, compared to fourteen in 2019.
The second milestone: The J&F settlement pushed total FCPA penalties — since the Act’s inception in 1977 — to over $20 billion. About 90 percent of that amount is attributable to enforcement actions over the last ten years.
Here’s a look at FCPA enforcement amounts by decades:
| Decade | Total Settlements |
| 70s | $50,000 |
| 80s | $6.3 million |
| 90s | $31 million |
| 2000s | $1.8 billion |
| 2010s | $15.4 billion |
| 2020s (so far) | $2.9 billion |
The full YTD FCPA Enforcement Report for companies and individuals is available on FCPA Blog+. Members also have access to the complete corporate enforcement index, the same tool we used to research this post.
1 Comment
It would be interesting to see the split between US domestic collections and from overseas as the notion continues to live that for a large part overseas companies are sponsoring US Treasury.
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