Anti-Bribery and Corruption
While there were eight Foreign Corrupt Practices Act (FCPA) enforcement actions in 2014 compared with 10 in 2012, penalties and settlements have skyrocketed in the past two years with roughly $692 million in penalties and settlements resulting from FCPA actions last year compared with approximately $172 million in 2013, according to the SEC. These larger fines and penalties are continuing into 2015. There also appears to be more ongoing FCPA investigations. At the same time, we are seeing an uptick in global anti-bribery and corruption enforcement actions. Additionally, we are witnessing an intensified focus by regulators on individuals and compliance gatekeepers.