Less Than Half of DOJ’s FCPA Individual Enforcement Actions Involve FCPA Charges, More Than Half Involve Two Countries

In his analysis of DOJ FCPA enforcement data, Mike Koehler identified 175 individual cases, of which only 80 (about 45%) involved individuals actually charged with substantive FCPA offenses or conspiracy to violate it, leaving 95 (about 55%) involving non-FCPA offenses in connection with alleged foreign bribery schemes, such as money laundering.