2016 was certainly one for the FCPA enforcement record books. There were 27 corporate enforcement actions with monetary fines and penalties of nearly $6 billion. This made 2016 the most active year on record. The end of 2016 brought several stunning FCPA enforcement actions including those involving Odebrecht and Teva Pharmaceuticals which largely contributed to this very large penalty amount.

Thomas Fox has practiced law for over 40 years. Tom writes the daily award-winning blog, the FCPA Compliance and Ethics blog and founded the Compliance Podcast Network. Tom leads the discussion on AI in...