In reference to the SEC’s recently released annual report for enforcement results for fiscal year 2023 (see here for the prior post) this headline by a for profit media company which generally publishes behind a paywall states “records show decline in new FCPA cases at SEC continues” with the teaser “lawyers say the continued downturn in new cases at the SEC’s foreign bribery unit could be related to DOJ guidance on self-disclosure and sanctions.”

My question is from where does this sh*t originate?

Set forth below is the SEC’s own data for FCPA enforcement actions from its four most recent annual reports.

  • FY23 – 11
  • FY22 – 6
  • FY21 – 5
  • FY20 – 7

In other words, where is the “decline,” where is the “continued downturn”?

When is this nonsense going to stop by paid journalists or other FCPA commentators (see here).

I sent the following e-mail five days ago to the journalist who published the story asking: “Please provide the corporate FCPA enforcement statistics you are referring to to support your headline assertion that there has been a “decline” in FCPA cases or a “downturn.”


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