In this memo:

- Enforcement Actions and Strategies

- Perennial Statutory Issues

- Compliance Guidance

- Unusual Developments

- Private Litigation

- Enforcement in the United Kingdom

- Conclusion

- Excerpt from Enforcement Actions and Strategies:

The 2014 FCPA enforcement year has been interesting to say the least. While the DOJ and SEC continue to prosecute individuals at a relatively steady pace, the big news concerns the government’s pursuit of corporate defendants. With a surge of large corporate enforcement actions towards the end of the year, 2014 has generated the second highest corporate penalty total in history despite the fact that the total number of corporate enforcement actions has remained roughly the same as 2013. As a result, average corporate penalties continue to steadily increase, reaching their highest levels ever in 2014.