The five year spike in Foreign Corrupt Practices Act (FCPA) enforcement activity appears to be leveling off.  That’s according to a report from Gibson Dunn.

The Department of Justice is on track to hit 14 FCPA enforcement actions for 2012, down from 23 in 2011 and 48 in 2012. The Securities and Exchange Commission is on track to hit 12 FCPA enforcement actions this year — down from 25 in 2011 and 26 in 2012.

But the leveling off doesn’t mean that FCPA enforcement is going away.

The Gibson Dunn report found the first sustained pattern of FCPA trial activity, increasing “private attorney general” enforcement, and serious policy debates between industry, executive, and legislative interests leading up to much-anticipated statutory guidance from government regulators.