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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Five numbers that show just how big the FCPA industry has become

How much has FCPA enforcement and compliance changed over the last decade? Ask anyone who’s been around, and they’ll probably say “a lot” or “completely.” Perhaps the most telling metric quantifying this change is the average size of a corporate FCPA resolution.

Looking at the past five years of FCPA enforcement history, a stunning picture emerges.

Here are the average FCPA corporate settlements (with the DOJ or SEC or both) from the past five years, according to data provided by FCPA Blog+:

  • 2016: $97,555,121
  • 2017: $152,322,050
  • 2018: $169,745,383
  • 2019: $207,419,460
  • 2020: $534,683,697

Companies are now paying an average of half a billion dollars to settle FCPA enforcement actions. That’s more than five times what it was just five years ago. It’s not quite exponential growth, but it’s not far off.

However, not every enforcement action involves mega-bucks. In 2020, Cardinal Health paid $8.8 million and Sargeant Marine paid $16 million to settle FCPA violations. But the big enforcement actions have gotten dramatically bigger.

It’s not just the penalties that have swelled, it’s also compliance staffing. Citibank now has 30,000 risk and compliance-related personnel

Yet, the FCPA compliance industry remains largely unregulated. As our editor at large said, “We should probably be asking not if ‘compliance officer’ will become a regulated profession, but when.”

How much bigger can big FCPA enforcement actions get?  Will the DOJ and SEC seek increasingly massive penalties from increasingly massive companies? Or have we reached the peak?

Goldman Sachs now sits number one on the FCPA Top Ten list. Will it be there for long? How many companies can afford a Goldman-sized $3.3 billion settlement

We’ll see whether FCPA settlement amounts will continue expanding, or if these astronomical figures will fall back to earth. 

All case values are based strictly on penalties assessed and disgorgement ordered by the DOJ and SEC as reflected in charging and settlement documents. A detailed methodology of how we calculate FCPA settlement amounts is here.

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