Earlier this summer the director of the Mintz Group (a private firm specializing in corporate investigations matters) referred me to a useful resource his firm has developed, an interactive “FCPA Map,” displaying in graphic and user-friendly from all the FCPA cases that have resulted in penalties, broken down by country, industry, and size of penalty (along with links to the court decisions or press releases announcing the resolution of each of the cases). All the information on this FCPA Map is publicly available and can be downloaded from other sources (including the DOJ’s website), but the interactive map is a helpful, user-friendly resource that I thought might be of interest to some of our readers (and may be especially useful for students). So I thought I’d give it a plug here.
[By the way, in case anyone is wondering: I have no relationship, financial or otherwise, with the Mintz Group. I’ve only met the director once, briefly, after he attended a lecture I delivered at the International Anti-Corruption Academy. Mentioning this may seem gratuitous, but on an anticorruption blog of all places, it’s probably important to address any concerns about conflicts of interest!]
I agree that the FCPA Map is a nice resource and fun to spend some time with. From my perspective though, a deficiency is that the shade of red is linked NOT to the number of FCPA enforcement actions in a country, but the settlement amounts associated with enforcement actions in the country. Thus for instance, Nigeria is deep red because several parallel enforcement actions all involved the $6 billion dollar Bonny Island LNG plant in Nigeria. Argentina is another good example. It is deep red because a PORTION of the Siemens conduct took place there. It appears that the map assigned the entire Siemens settlement amount to Argentina. This isn’t necessarily the fault of the map because DOJ and SEC enforcement actions involving multiple countries rarely apportion fine and penalty amounts.