One of the more useless annual exercises that folks go through is to detail out the Foreign Corrupt Practices Act (FCPA) enforcement statistics each year and use that information to discuss whether the Justice Department and Securities and Exchange Commission are prosecuting less or more FCPA cases … as if such parsing had any meaning. Last year was perceived to be a down year, as there were “only” 10 Justice Department and 10 SEC FCPA enforcement actions. The problem with that data point has been borne out over the past 3 months, amid a plethora of new cases announced.
