The small percentage of FCPA enforcement actions as a total of overall SEC enforcement actions in FY2023 was not an aberration.
In FY2022, FCPA enforcement actions comprised just 1% of the SEC’s overall enforcement actions; in FY2021, FCPA enforcement actions comprised just 1% of the SEC’s overall enforcement actions; in FY2020 FCPA enforcement actions comprised just 2% of the SEC’s overall enforcement actions; in FY2019 FCPA enforcement actions comprised just 3% of the SEC’s overall enforcement actions; in FY2018 FCPA enforcement action comprised just 3% of the SEC’s overall enforcement actions; and in FY2017 FCPA enforcement actions comprised just 4% of the SEC’s overall enforcement actions.
In short, based on the SEC’s own data, FCPA enforcement actions comprise a minuscule percentage of its overall enforcement actions.
What happens in those enforcement actions is also relevant in addressing the question of whether the SEC really even needs a specific FCPA unit.
Source: Does The SEC Even Need A Specific FCPA Unit? – FCPA Professor
