These charts identify, both per year and over the life of the FCPA, the frequency with which the government requires companies to adopt new compliance policies and procedures as part of a resolution of FCPA-related claims. Compliance data is aggregated by Entity Group and then by FCPA Matter and is adjusted to avoid double counting that may otherwise occur when the same or affiliated corporate entities are sued in separate Enforcement Actions within a single Matter based on the same underlying misconduct. Data is aggregated by filing date, not date of resolution. If both "compliance obligation" and "no compliance obligation" have a 0 value for a particular year, that means that no FCPA-related Enforcement Actions were filed against entity defendants in that year. See About Us - Datasets for definitions of "Enforcement Action" and "FCPA Matter." See About Us - Definitions for the definition of "Entity Group."

These charts indicate, both per year and over the life of the FCPA, whether companies with ongoing compliance obligations are required to report to the government regarding their efforts to implement new compliance policies and procedures and, if so, what those reporting obligations looks like. "Outside monitor" means the company is required to hire an independent third-party monitor to evaluate the entity's efforts to implement new compliance policies and procedures and to report to the government regarding those efforts. "Self-reporting" means the company is required to provide intermittent reports to the government regarding its efforts to implement new compliance policies and procedures. A "hybrid" reporting obligation is a combination of both self-reporting and an outside monitor, and often takes the form of an outside monitor for 18 months followed by 18 months of self-reporting. "No reporting" means the company is not required to provide the government with any status reports about its ongoing compliance obligations. Data is aggregated by Entity Group and then by FCPA Matter in order to avoid double counting that may otherwise occur when the same or affiliated corporate entities are sued in separate Enforcement Actions within a single Matter based on the same underlying misconduct. A particular type of reporting obligation is therefore counted only once per Entity Group per Matter. If affiliated entities undertake multiple, different reporting obligations, the "highest" obligation is applied to the Entity Group based on the following ranking: outside monitor, hybrid, self-reporting, no reporting. If "self-reporting," "outside monitor," "hybrid" and "no reporting" all have a 0 value for a particular year, that means that either no compliance obligations were imposed on entity defendants in that year, or that no FCPA-related Enforcement Actions were filed against entity defendants in that year. Data is aggregated by filing date, not date of resolution. See About Us - Datasets for definitions of "Enforcement Action" and "FCPA Matter." See About Us - Definitions for the definition of "Entity Group."