The Justice Department and the SEC had a record year in FCPA enforcement — the largest amount of penalties against corporate defendants and the most individuals charged in one year. DOJ’s Ericsson and MTS settlements resulted in nearly $2 billion in recoveries. DOJ had several trial victories as well in winning the Hoskins and Lambert trials. Along the way, DOJ’s FCPA Corporate Enforcement policy has been applied consistently and DOJ has tweaked various policies to increase transparency and certainty. As FCPA enforcement matures, DOJ’s consistency provides greater clarity and guidance as to expectations.