The graphic is from the 2025 report of the Department of Justice’s Fraud Section. Hard to draw any conclusions about the impact of the Trump Administration’s downgrading FCPA enforcement as the cases largely reflect work begun in Biden Administration and earlier. Perhaps the fact FCPA cases yielded $122.8 million, far in excess of what it cost to prosecute them, will lead Trump Administration officials to reconsidere cutbacks in FCPA enforcement actions.
Link to the full report here.
GAB | The Global Anticorruption Blog 
With FCPA inquiries lasting – on average 4-5 years – it is common for inquiries that began during one administration lead to an enforcement action in another administration. Have you typically “discounted” to account for this dynamic in the past? In terms of the “cutback” in enforcement actions, there were more DOJ corporate enforcement actions in 2025 compared to 2021 and 2015 and the last 9 months has been one of the more active periods of FCPA trials in the statute’s nearly 50 years.