Since 2000, the Justice Department and SEC have entered into 290 publicly disclosed DPAs or NPAs, according to a recent analysis from law firm Gibson Dunn. Over that period, DPAs and NPAs have netted the government more than $42 billion in penalties and recoveries.

The start of 2014 alone saw monetary penalties of nearly $3.6 billion arising from 12 prosecution agreements: seven DPAs and five NPAs, including one negotiated solely by the SEC. This year’s monetary penalties already exceed the 2013 total of $2.9 billion. Furthermore, the analysis did not include the latest DPA and $86 million penalty Lloyds Banking Group reached July 28 with the Justice Department to resolve acts of false reporting and attempted manipulation of the London Interbank Offered Rate (LIBOR).

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...