Last Friday we wrote about a record number of Foreign Corrupt Practices Act enforcement actions against corporations this year, based on a list on the U.S. Securities and Exchange Commission website.
While a record number of FCPA enforcements was set, we need to clarify that the number included some Department of Justice enforcements, and that some SEC numbers were wrong.
Because we counted each listing in the SEC index rather than the number of companies and individuals in the listings, both in 2016 and in the previous record year 2010, our numbers did not reflect actual enforcement actions.
