97 Companies Under Investigation For FCPA-Related Activities

The FCPA Blog has a digest of 2022 enforcement actions with a link to a more detailed report. According to the digest, the DOJ and SEC imposed $1.5 billion in financial penalties to resolve actions against eight companies, considerably more than 2021, when four companies paid $282 million, but less than 2020’s $6.4 billion levied against 122 companies. At the end of 2022 there were 97 companies with open disclosed Foreign Corrupt Practices Act-related investigations. The corporate enforcement actions were against KT Corporation, Stericycle, Inc., Glencore plc, Tenaris, S.A., GOL Linhas Aéreas Inteligentes S.A., Oracle Corporation, ABB Ltd, and Honeywell International Inc. One individual, a former Herbalife executive, settled FCPA offenses with the SEC after he didn’t appear and the court entered a default judgment against him. Two individuals pleaded guilty and four were indicted. No individuals were sentenced for FCPA offenses in 2022.