Is the SEC Finished with NPAs and DPAs in FCPA Cases?

In 2010, the SEC introduced Deferred Prosecution Agreements (DPAs) and Non-Prosecution Agreements (NPAs) as part of a strategy to strengthen its enforcement efforts by encouraging cooperation from companies and individuals. However, since then, the SEC has rarely used these tools, employing DPAs only twice and NPAs three times, mostly in FCPA enforcement actions. The last use of either agreement was in 2016 in cases involving Nortek and Akamai Technologies. Since then, the SEC has not returned to NPAs or DPAs, raising questions about whether the agency has moved away from these agreements for resolving FCPA cases.