• In 2004, the DOJ collected about $11 million in criminal fines. In 2009 and 2010 combined, the DOJ collected nearly $2 billion in criminal fines.

  • The FBI has trained a special investigative unit for FCPA violations.

  • FCPA enforcement officials currently have more than 150 criminal and 80 civil investigations underway.

  • New FCPA whistleblower provisions increase risks.

  • In 2010, 52 individual businesspeople were indicted, sentenced, or convicted and are awaiting sentencing for FCPA violations.

  • Enforcement officials resolved 6 FCPA enforcement actions in 2002. In 2010, they resolved 71.

  • In 2010 alone, five FCPA settlements exceeded $100 million.

  • The amount of FCPA penalties tripled between 2009 and 2010.

  • Individuals are facing significant FCPA fines and jail time for authorizing improper payments.

  • FCPA actions are increasingly brought against small and medium-sized companies as well as high-profile multinational corporations.


The global marketplace now faces heightened enforcement of the U.S. Foreign Corrupt Practices Act (FCPA) and similar anti-corruption rules. Unprecedented FCPA penalties, the passage of the UK Bribery Act, the introduction of a special FBI unit to investigate bribery, and new FCPA whistleblower mechanisms highlight the need for companies to implement effective compliance programs. Enforcement officials expect such programs to be an integral part of a company’s operations. Without these programs, companies and their executives face the potential for severe fines and penalties, damaged reputations, shareholder derivative suits, and even individual jail time.

Cairo, Egypt