Significantly fewer cases were settled from 2018-21 than were settled in the prior three-year period.

  • Many of the largest cases over the past three years have originated from investigations by non-U.S. regulators.
  • The number of cases stemming from voluntary disclosures has gone down.
  • Non-U.S. companies continue to face challenges in fulfilling cooperation and remediation expectations of U.S. regulators.

FCPA 2022
FCPA 2021
FCPA 2020