Stanford Law School and Sullivan & Cromwell Launch Foreign Corrupt Practices Act Clearinghouse


Publish Date:
February 17, 2016
  • Terry Nagel
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Stanford Law School and Sullivan & Cromwell Launch Foreign Corrupt Practices Act Clearinghouse 1
The Foreign Corrupt Practices Act Clearinghouse helps build awareness of the fight against global corruption.

Stanford Law School and Sullivan & Cromwell LLP announced today (February 17, 2016) the launch of the Foreign Corrupt Practices Act Clearinghouse (FCPAC), a public database that aggregates and curates source documents and provides analytic tools related to enforcement of the Foreign Corrupt Practices Act (FCPA).

The FCPAC provides business leaders, law firms, policymakers, scholars, judges, the media and the general public with a comprehensive database of enforcement actions and information related to the FCPA, all at no charge. Users can search and sort data about FCPA enforcement actions according to their individual needs and interests. They can view original documents, access relevant laws and precedent, and read articles about FCPA compliance and enforcement. The database is available at

The FCPA has to date generated more than 400 enforcement actions by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC), implicating transactions in more than 100 countries. Defendants in these prosecutions have paid fines and penalties in excess of $7 billion, and the government has signaled its intention to substantially increase its enforcement efforts. Foreign nations are also intensifying their efforts to combat corruption by enacting new legislation and by participating in multilateral conventions and working groups aimed at reducing the incidence of bribery on a global basis.

“Corruption is a pervasive and growing problem,” added Professor Joseph A. Grundfest, the principal investigator for the FCPAC. “Companies facing FCPA exposure will benefit greatly from the detailed insight available through the Clearinghouse. So, too, will policymakers and enforcement agencies battling to contain the spread of bribery in international commercial relations.” Grundfest is the W.A. Franke Professor of Law and Business at Stanford Law School (SLS) and a senior faculty member at the Arthur and Toni Rembe Rock Center for Corporate Governance (Rock Center) at SLS.

Some of the ways users can benefit from the FCPAC are:

  • Anyone will be able to access the “Resources” section of the website, which provides links to relevant laws, legislative history, FCPA guidance and compliance, FCPA-related blogs and forums, the websites of federal agencies involved in FCPA investigations and prosecutions, and more.
  • Companies under investigation for FCPA violations and their law firms will be able to construct narrowly tailored searches in the “Enforcement Actions” database to identify and analyze similar fact patterns; anticipate potential dispositions, sanctions and sentences; and monitor the impact of cooperation and self-reporting.
  • Business leaders and compliance professionals will be able to monitor the changing compliance landscape to ensure that their policies and procedures conform to minimum standards elucidated by the SEC and DOJ.
  • Academics and the media will be able to conduct empirical analyses of FCPA enforcement actions and search for general trends on the FCPAC’s “Statistics and Analytics” pages.

The FCPAC is a public service provided through the Rock Center, which is a joint initiative of Stanford Law School and the Stanford Graduate School of Business. The database and website were created by scholars at SLS working in collaboration with Sullivan & Cromwell’s lawyers. The Rock Center also provides support.

Stanford Law School has been at the forefront of the creation of law-related databases that support empirical research for scholars, practitioners and policymakers and produce important real-world applications. Among the other important databases it has launched are the Securities Class Action Clearinghouse, which catalogs securities class actions; the Intellectual Property Litigation Clearinghouse, which now operates as a commercial venture called Lex Machina offering real-time data on IP litigation; the Stanford Securities Litigation Analytics project, which tracks and collects data on securities class action litigation and SEC enforcement actions; and the Global Class Actions Exchange, which provides country reports, statutes and rules concerning collective litigation practices.

Sullivan & Cromwell strives to ensure that its clients and the public are kept abreast of recent developments in the law. Recent initiatives include its AML and Sanctions Watchlist, a blog dedicated to developments in the constantly evolving and increasingly complex areas of anti-money laundering and sanctions enforcement and compliance, and Dodd-Frank Developments, a web tool that tracks regulatory developments under the Dodd-Frank Wall Street Reform and Consumer Protection Act.

About Stanford Law School

Stanford Law School is one of the nation’s leading institutions for legal scholarship and education. Its alumni are among the most influential decision makers in law, politics, business and high technology. Faculty members argue before the Supreme Court, testify before Congress, produce outstanding legal scholarship and empirical analysis, and contribute regularly to the nation’s press as legal and policy experts. Stanford Law School has established a new model for legal education that provides rigorous interdisciplinary training, hands-on experience, global perspective and focus on public service, spearheading a movement for change.

About the Arthur and Toni Rembe Rock Center for Corporate Governance

The Arthur and Toni Rembe Rock Center for Corporate Governance was created to advance the understanding and practice of corporate governance in a cross-disciplinary environment where leading academics, business leaders, policymakers, practitioners and regulators can meet and work together.

About Sullivan & Cromwell LLP

Sullivan & Cromwell LLP (S&C) provides the highest-quality legal advice and representation to clients around the world. The results the firm achieves have set it apart for more than 130 years and have become a model for the modern practice of law. Today, S&C is a leader in each of its core practice areas and in each of its geographic markets. S&C comprises approximately 800 lawyers who serve clients around the world through a network of 12 offices, located in leading financial centers in Asia, Australia, Europe and the United States. The firm is headquartered in New York.


Terry Nagel, Stanford Law School,, (415) 723-2232

Katherine J. Peters, Sullivan & Cromwell LLP,, (212) 558-3567