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The Top Ten List Of FCPA Disgorgement Amounts

top ten

Everybody, it seems, likes “Top Ten” lists.

This post highlights the top ten corporate FCPA disgorgement (and prejudgment interest) amounts in FCPA history.

The list highlights net FCPA disgorgement (and prejudgment interest) amounts after consistently accounting for (unlike other lists out there) certain credits or deductions in enforcement actions for foreign law enforcement actions or forfeiture amounts paid to the DOJ in a parallel proceeding.

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Issues To Consider From The Fresenius Enforcement Action

Issues

This previous post went in-depth into the approximate $232 million Fresenius FCPA enforcement action and this post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted in this prior post, Fresenius disclosed its FCPA scrutiny in August 2012. Thus from start to finish, its FCPA scrutiny lasted an unconscionable 6.5 years.

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Friday Roundup

Roundup

Banking bar, Kokesh related, OECD shaming, quotable, downfall, and listening in. It’s all here in the FCPA roundup.

Banking Bar

The Federal Reserve recently announced “that it is prohibiting Tim Leissner and Ng Chong Hwa, also known as Roger Ng, from the banking industry for their participation in a scheme to illegally divert billions of dollars from a Malaysian sovereign wealth fund. Leissner was also fined $1.42 million and consented to the permanent ban.”

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SEC FCPA Enforcement – 2018 Year In Review

SEC

Foreign Corrupt Practices Act enforcement, it’s not just about the DOJ.

Granted, as a civil enforcement agency the SEC’s sticks are less sharp than the DOJ’s, but the SEC also claims a significant piece of the FCPA enforcement pie (query whether it should – but that is a subject for another day – for instance as discussed in “The Story of the Foreign Corrupt Practices Act” the SEC wanted no part in enforcing the FCPA’s anti-bribery provisions).

This previous post highlighted various corporate enforcement statistics from 2018, this post focused more specifically on DOJ enforcement in 2018, and this post goes in-depth into various facts and figures relevant to SEC FCPA enforcement in 2018.

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Issues To Consider From The Vantage Drilling Enforcement Action

Issues

This previous post went in-depth into the rather unusual Vantage Drilling Foreign Corrupt Practices Act enforcement action and this post continues the analysis by highlighting additional issues to consider.

Timeline

As highlighted here, in July 2015 (or shortly thereafter) Vantage Drilling voluntarily disclosed to the DOJ/SEC. Thus, from start to finish the company’s FCPA scrutiny lasted approximately 3.5 years. While this is below recent averages of approximately 4.5 years, it is still too long for FCPA scrutiny to last particularly since Vantage Drilling, in the words of the SEC:

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