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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

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

2021 FCPA Enforcement Index

In 2021, the DOJ and SEC brought FCPA enforcement actions against four companies and imposed financial penalties totaling $282 million. For comparison, in 2020, 12 companies paid a record $6.4 billion to resolve FCPA cases.

The four corporate FCPA enforcement actions were Amec Foster Wheeler Energy Limited, Credit Suisse Group AG, Deutsche Bank AG, and WPP plc.

Total penalties in 2021 were the lowest since 2015. The average settlement size in 2021 was $70.5 million.

In comparison, in 2020, 12 companies paid a total of $6.4 billion. The average settlement that year was $533 million.

In 2019, 14 companies paid $2.9 billion to resolve FCPA cases with an average settlement of $207 million.

The FCPA Blog top ten list of largest FCPA settlements was unchanged in 2021.

In 2021, four companies received declinations from the DOJ, SEC, or both.

Nine issuers disclosed new FCPA investigations. According to the companies, all nine new FCPA investigations remain active and open.

According to data from FCPA Tracker, at the end of 2021, there were 102 companies with open disclosed FCPA-related investigations.

One individual, former Goldman Sachs executive Asante Berko, settled FCPA offenses with the SEC.

Two individuals were sentenced, three pleaded guilty, and three were indicted for FCPA offenses in 2021.

Click here to view the full 2021 FCPA Enforcement Report on FCPA Blog+. It includes a synopsis and links to relevant content for corporations and individuals beginning in 2008.

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