by Ralph Stobwasser, Anna Bleazard, Arnold Castillo, Greg Hallahan, Rongcheng Chen, Ed Westerman

The debate around the Foreign Corrupt Practices Act (FCPA) is intensifying—but it continues to focus on the wrong question. Much of the discussion is framed around who is being prosecuted: whether European companies are disproportionately targeted, or whether US businesses are disadvantaged. That framing misses the real driver of exposure. The more relevant question for organizations is where bribery is actually occurring, and therefore where risk is concentrated. 

Our global white paper takes a different lens, mapping nearly a decade of FCPA enforcement by the geography of the underlying conduct rather than the nationality of the defendant. The analysis shows that bribery risk is not evenly distributed across global markets. Instead, it is concentrated in specific regions and sectors where companies interact with state-owned enterprises, public procurement systems, and complex regulatory environments. These structural conditions, rather than nationality, are what consistently drive anti-corruption risk. 

While FCPA enforcement has been recalibrated following the 2025 policy reset, the underlying geography of bribery remains unchanged. Organizations continue to operate in the same high-risk jurisdictions, with the same exposure to intermediaries, third-party networks, and cross-border operating models. As a result, compliance, legal, and investigations teams need to focus less on enforcement narratives, more on where risk actually sits and align their programs accordingly. 

Key findings from the analysis 

• Bribery risk is geographically concentrated, not global 
  Exposure is highest across South America, Sub-Saharan Africa, MENA, and parts of Asia 
• A small number of jurisdictions drive a significant share of cases 
  South America alone appears in 30 of 82 enforcement actions, with Brazil accounting for 25 
• Sub-Saharan Africa (22 cases) and MENA (21 cases) 
  These regions represent core high-risk environments, driven by extractive industries, infrastructure, and sovereign-linked activity 
• Asia reflects a distinct risk profile (41 cases) 
  Primarily linked to market access, licensing, and blurred state–private sector boundaries 
• Multi-regional exposure is common 
  41% of cases involve bribery across multiple jurisdictions, often enabled by third-party intermediaries and global operating models 
• Europe is underrepresented in the location of misconduct 
  Appearing in just 5% of cases, highlighting the disconnect between where companies are headquartered and where bribery occurs 
• Risk is structural, not nationality-based 
  It is driven by state ownership, resource dependency, public procurement, and governance frameworks—not by the origin of the company