This chart identifies the number of Enforcement Actions the SEC or DOJ initiated per year, for each year since the statute's enactment. By hovering over a year, users can see the number of Enforcement Actions filed by the SEC and the number of Enforcement Actions filed by the DOJ. If the SEC and DOJ jointly file an Enforcement Action, that action is counted once for the SEC and once for the DOJ. See About Us - Datasets for a definition of "Enforcement Action." There are many ways to define an FCPA enforcement action and to count the number of such actions filed per year. This graphic presents one possibility among several.
This chart identifies groups of related Enforcement Actions the SEC or DOJ initiated per year, for each year since the statute's enactment. Enforcement Actions are "related" if they share a common locality, time period, and bribery scheme. Data is culled from FCPA Matters with at least one Enforcement Action; Matters involving only Investigations are excluded from this analysis. The initiation date is based on the earliest initiation date of all Enforcement Actions linked to the Matter. FCPA Matters can include actions filed by the DOJ and actions filed by the SEC (or actions filed jointly by both agencies). By hovering over a year, users can see the number of FCPA Matters that include only SEC actions, the number of FCPA Matters that include only DOJ actions, and the number of FCPA Matters that include both SEC and DOJ actions (or actions filed jointly by both agencies). See About Us - Datasets for definitions of "Enforcement Action" and "FCPA Matter." There are many ways to define an FCPA enforcement action and to count the number of such actions filed per year. This graphic presents one possibility among several.
This chart identifies the number of defendants the SEC or DOJ charged per year with FCPA-related offenses, for each year since the statute's enactment. Individuals and entities that resolve potential FCPA-related claims through non-prosecution agreements are counted as defendants for purposes of this graphic. Each defendant to an enforcement action is counted separately, regardless of affiliations among entity defendants and regardless of whether the same entity is sued multiple times by the same agency in the same year (for example, in an SEC federal court action and an SEC administrative action). All defendants to all FCPA-related actions are included in the count, even if the action is not listed on the SEC or DOJ website, and even if no FCPA claims are raised therein. The case against a defendant is deemed filed in the year in which the document charging that particular defendant with FCPA-related offenses is filed. If no charging document is filed, the case is deemed filed in the year of the earliest press release, negotiated resolution, or pertinent case filing. There are many ways to define an FCPA enforcement action and to count the number of such actions filed per year. This graphic presents one possibility among several.
This chart identifies the number of publicly disclosed Investigations initiated each year since enactment of the FCPA. Only investigations that are publicly disclosed in advance of resolution are included in this graphic. A single Investigation can consist of several related investigations initiated by the company, the SEC, and/or the DOJ. The initiation date of the Investigation as a whole is the earliest initiation date of the related company, SEC, and/or DOJ investigations. See About Us - Datasets for a definition of "Investigation." See About Us – Definitions for the definition of an Investigation's "Initiation Date."
This chart identifies the number of Entity Groups that publicly disclosed new FCPA-related Investigations per year, for each year since the statute's enactment. Entity Groups are aggregated annually according to the earliest initiation date of any Investigation involving that Entity Group that is part of a single FCPA Matter, regardless of whether the investigation is initiated by the company, the SEC, the DOJ or unspecified U.S. authorities. Entity Group Investigations that are part of different FCPA Matters will be counted separately if they are initiated in different years. For purposes of this graphic, Entity Groups that the SEC or DOJ charged with FCPA-related violations but for which there is no publicly disclosed investigation in the Clearinghouse database are excluded from the counts because the investigation initiation dates are unknown. See About Us - Datasets for the definition of "Investigation." See About Us – Definitions for definitions of "Initiation Date" and "Entity Group."
This chart identifies the number of Entity Groups the SEC or DOJ charged per year with FCPA-related violations, for each year since the statute's enactment. Entity Groups are aggregated annually according to the earliest initiation date of any Enforcement Action filed against the Entity Group within a single FCPA Matter. An Entity Group that is sued multiple times in multiple different years as part of separate FCPA Matters will be counted once per initiation year. See About Us - Datasets for the definitions of "Enforcement Action" and "FCPA Matter." See About Us – Definitions for the definition of "Entity Group."
These charts identify the number of Entity Groups and individuals the SEC or DOJ charged per year with FCPA violations, for each year since the statute's enactment. There are many ways to count FCPA proceedings. For purposes of this graphic, multiple proceedings brought by the same agency in the same year against the same or affiliated entity defendants based on the same underlying bribery scheme are lumped together and counted as a single proceeding. Each unique individual defendant that is sued in a single year is counted separately. While the Clearinghouse database does include proceedings that are FCPA-related even if they allege no FCPA violations, those proceedings are excluded from this analysis. Cases are deemed filed in the year that the charging document is filed. If no charging document is filed, the case is deemed filed in the year of the earliest press release, negotiated resolution, or other pertinent case filing. Note that this graphic relies on a unique methodology for counting FCPA proceedings that does not align with the definition of an "Enforcement Action" on the About Us - Datasets portion of this website. See About Us – Definitions for the definition of "Entity Group."
Foreign and Domestic Entity Groups per Year (FCPA-Related): This chart identifies the number of Entity Groups the SEC or DOJ charged per year with FCPA-related violations, for each year since the statute's enactment. Entity Groups are aggregated annually according to the earliest initiation date of any Enforcement Action filed against the Entity Group within a single FCPA Matter. An Entity Group that is sued multiple times in multiple different years as part of separate FCPA Matters will be counted once per initiation year. The Entity Group is assigned to either "foreign" or "domestic" based on the attributes of the parent entity. If the parent is headquartered or incorporated in the United States, the Entity Group is deemed to be "domestic." If the parent is both headquartered and incorporated outside of the United States, the Entity Group is deemed to be "foreign." See About Us - Datasets for the definitions of "Enforcement Action" and "FCPA Matter." See About Us – Definitions for the definition of "Entity Group."