US government enforcement of the Foreign Corrupt Practices Act (FCPA) in 2018 remained robust, and the trend of increasing multi-jurisdictional cooperation and enforcement continued throughout the year. In the United States, the 33 combined individual and corporate FCPA enforcement actions concluded by the US Department of Justice (DOJ) and Securities and Exchange Commission (SEC) in 2018 were largely consistent with the average number of enforcement actions brought over the last seven years. The US $2.91 billion in monetary sanctions levied in corporate FCPA enforcement matters in 2018 reached a record high, although the chart-topping $1.78 billion penalty imposed as part of the Petrobras settlement accounts for more than half of this amount. Outside the United States, a number of countries continue to substantially enhance the legal and regulatory structure for international anti-corruption enforcement, including by passing legislation establishing corporate liability for certain types of bribery offenses and authorizing prosecutors to enter deferred prosecution agreements or other negotiated resolutions with companies accused of bribery.

Click here to read more in our 2018 FCPA/Anti-Corruption Year in Review, which includes summaries of the following developments:

  • Enforcement Statistics and Trends
  • FCPA Policy and Legal Developments
  • 2018 Corporate Settlements
  • 2018 Individual Enforcement Actions
  • 2019 Enforcement To Date
  • New FCPA Investigations
  • Significant Collateral Litigation
  • International Developments
  • World Bank and Other International Financial Institution Enforcement