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Editors

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

2022 FCPA Enforcement Index

In 2022, the DOJ and SEC brought FCPA enforcement actions against eight companies and imposed financial penalties totaling $1.5 billion. For comparison, in 2021, four companies paid $282 million to resolve FCPA cases, and in 2020, 12 companies paid a total of $6.4 billion.

The eight corporate FCPA enforcement actions this year were KT Corporation, Stericycle, Inc., Glencore plc, Tenaris, S.A., GOL Linhas Aéreas Inteligentes S.A., Oracle Corporation, ABB Ltd, and Honeywell International Inc.

Total financial settlements in 2022 were the second lowest since 2015, after 2021.

In 2022, five companies received declinations from the DOJ, SEC, or both.

The FCPA Blog top ten list of largest FCPA settlements saw the arrival of Glencore to the number ten spot with its $700 million settlement in 2022.

Five issuers disclosed new FCPA investigations. According to the companies, four of the new FCPA investigations remain active and open.

According to data from FCPA Tracker, at the end of 2022, there were 97 companies with open disclosed FCPA-related investigations.

One individual, former Herbalife executive Jerry Li, settled FCPA offenses with the SEC after he didn’t appear and the court entered a default judgment against him.

One individual, former Goldman Sachs executive Roger Ng, was convicted FCPA offenses.

Two individuals pleaded guilty and four were indicted. No individuals were sentenced for FCPA offenses in 2022.

Lawrence Hoskins’s acquittal on FCPA offenses was affirmed; his conviction on money laundering-related counts was left in place, for which he was sentenced to 15 months in prison.

Two individuals, Roger Richard Boncy and Joseph Baptiste, had their FCPA changes dismissed.

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View the full 2022 FCPA Enforcement Report on FCPA Blog+. It includes a synopsis and links to relevant content for corporations and individuals beginning in 2008.

If you haven’t subscribed yet, I encourage you to do so. It’s the easiest way to research FCPA enforcement actions (and more). We use it ourselves every day at the FCPA Blog.

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