Despite Rhetoric On Individual Accountability, Recent FCPA Enforcement Has Targeted Entities

With ample bravado, in recent years the FCPA unit of the DOJ and the SEC have proclaimed that holding individuals accountable for foreign bribery schemes is of "critical importance," with the FCPA saying "it is unambiguously this department's first priority" to prosecute individuals in corporate criminal matters. Reviewing the enforcement record, however, one sees that the volume of FCPA enforcement activity with respect to individuals has steadily declined in the last three years.