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Harry Cassin
Publisher and Editor

Andy Spalding
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Jessica Tillipman
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Bill Steinman
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Richard L. Cassin
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Elizabeth K. Spahn
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Cody Worthington
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Julie DiMauro
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Thomas Fox
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Marc Alain Bohn
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Bill Waite
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Russell A. Stamets
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Richard Bistrong
Contributing Editor

Eric Carlson
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Is there a compliance crisis coming?

It’s budgeting season for many companies, and word on the street is that things aren’t looking good for compliance teams. It can be summed up by an email I received from a compliance head at a Fortune 500: “We are being asked to cut back this year.”

It’s been a difficult few years. Pandemic, wild stock volatility, inflation, shadows of a recession. All of these things take a toll on corporate budgets. 

On the other hand, some corporate profits have never been higher; up nearly 10 percent year-on-year at Microsoft, and a similar upside story at Chevron, Walmart, McKesson, and others. 

So, what’s driving the cuts to compliance budgets? 

Well, enforcement is way, way down.

In 2020, total FCPA settlements topped $6.4 billion. In 2021, that fell to a comparatively tiny $282 million. 

Enforcement totals for 2022 bounced back a bit to $1.5 billion, and so far in 2023 we’ve seen settlements of just $300 million. 

Enforcement actions this year have also been interestingly small. The largest (not counting Ericsson’s DPA breach) is $62 million paid by Koninklijke Philips. Three of the six settlements this year have been under $10 million. Gartner’s $2.5 million resolution last month was the smallest corporate FCPA settlement since 2018. 

Is compliance slowly falling out of executive talking points without the headline-grabbing FCPA enforcement actions?

It certainly seems to be the case that it is harder to justify big compliance budgets than it used to be. 

Alternatively, this could be a needed market correction. Compliance budgets swelled in headcount and dollars after the major compliance scandals of the late-2010s and a string of FCPA mega-settlements. 

Who knows the actual reason, but if companies begin to feel comfortable cutting compliance budgets, the logical end isn’t good: less compliance and more corruption.

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