This chart identifies the total and average monetary sanctions imposed per year on Entity Groups in FCPA-related Enforcement Actions, for each year since the statute's enactment. Sanctions are aggregated by Entity Group and then by FCPA Matter. Sanctions may include amounts paid to foreign regulators in a global settlement if they were imposed and credited by U.S. regulators. Where it is possible to isolate sanctions, only sanctions attributable to FCPA-related misconduct are included in the total (and sanctions attributable to unrelated misconduct (e.g. Libor fraud) are excluded). For purposes of calculating the total, sanctions are adjusted to avoid double counting that could otherwise occur when, for example, sanctions are imposed jointly and severally on multiple defendants or a single sanction imposed on a parent entity is deemed to resolve claims against multiple different subsidiaries in multiple different Enforcement Actions. However, when two different Entity Groups (or an Entity Group and individual) are jointly and severally liable for the same penalty, then the penalty is counted in full for each defendant when calculating the average. Sanctions are aggregated annually according to the earliest initiation date of any Enforcement Action filed against the Entity Group within a single FCPA Matter. A $0 value for a particular year could mean that no sanctions were imposed or, alternatively, that no FCPA-related Enforcement Actions were filed against Entity Groups that year. For purposes of calculating an annual average, Entity Groups that were not convicted or that had their conviction vacated or plea dismissed were excluded from the analysis. See About Us - Datasets for definitions of "Enforcement Action" and "FCPA Matter." See About Us - Datasets – Definitions for the definition of "Entity Group."

This chart identifies the total and average monetary sanctions imposed per year on individual defendants in FCPA-related Enforcement Actions, for each year since the statute’s enactment. Sanctions may include amounts paid to foreign regulators in a global settlement if they were imposed and credited by U.S. regulators. Where it is possible to isolate sanctions, only sanctions attributable to FCPA-related misconduct are included in the total (and sanctions attributable to unrelated misconduct (e.g. Libor fraud) are excluded). For purposes of calculating the total, sanctions are adjusted to avoid double counting that could otherwise occur when sanctions are imposed jointly and severally on multiple defendants. However, for purposes of calculating the average, sanctions are counted in full for each individual defendant, even if the sanctions are joint and several. Sanctions are aggregated annually according to each defendant’s charging date. A $0 value for a particular year could mean that no sanctions were imposed or, alternatively, that no FCPA-related Enforcement Actions were filed against individual defendants that year. For purposes of calculating an annual average, individuals who were not convicted, who were convicted but whose sanctions are unknown (e.g. because they are fugitives or because their case is ongoing or sealed), or who had their conviction vacated or plea dismissed were excluded from the analysis. See About Us - Datasets for a definition of "Enforcement Action."

This chart presents two different datasets. First, the chart identifies the total monetary sanctions imposed by U.S. regulators in FCPA-related Enforcement Actions, per year over the life of the FCPA. Sanctions may include amounts paid to foreign regulators in a global settlement if they were imposed and credited by U.S. regulators. Where it is possible to isolate sanctions, only sanctions attributable to FCPA-related misconduct are included in the total (and sanctions attributable to unrelated misconduct (e.g. Libor fraud) are excluded). Sanctions are culled from Enforcement Actions linked to an FCPA Matter and are adjusted to avoid double counting that could otherwise occur when, for example, sanctions are imposed jointly and severally on multiple defendants or a single sanction imposed on a parent entity is deemed to resolve claims against multiple different subsidiaries in multiple different Enforcement Actions. Sanctions are aggregated annually according to the filing date, not the date of resolution. A $0 value for a particular year could mean that no sanctions were imposed or, alternatively, that no FCPA-related Enforcement Actions were filed that year.

Second, this chart identifies the total alleged bribery payments disclosed in FCPA-related Enforcement Actions, per year over the life of the FCPA. Bribery payments are culled from Enforcement Actions linked to an FCPA Matter, and are adjusted to avoid double counting that could otherwise occur when, for example, the same or affiliated defendants are sued in different Enforcement Actions for the same underlying bribery scheme. Bribery payments are aggregated annually according to the filing date, not the year in which the bribes were paid. Offers or promises to pay bribes that are not actually paid are excluded from the total to the extent they can be segregated. Bribery totals include all completed bribery payments that allegedly violate any provision of the FCPA (including bribery payments that are made to private individuals in violation of the books and records or internal controls provisions of the FCPA). The data used to generate this graphic were culled from publicly available documents filed in connection with the Enforcement Actions, and may not reflect all bribery payments that were offered or made. A $0 value for a particular year means that no bribery payments were made or, alternatively, that no FCPA-related Enforcement Actions were filed in that year.

FCPA Matters with unknown bribery amounts or sanctions are excluded from this analysis. See About Us - Datasets for a definition of "FCPA Matter."

This chart identifies the frequency of the average monthly cost of Investigations. The vertical/Y-axis is not linear in an attempt to capture the full spectrum of average monthly costs. Only resolved Investigations with reasonably complete disclosures regarding Investigation Costs are included in this analysis. See About Us - Definitions for See About Us - Definitions for definitions of "Investigation Costs" and "Estimated Length of Investigation.".