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Corporate FCPA Repeat Offenders

As highlighted in this post, 13 companies have resolved FCPA enforcement actions – not once – but twice. Four of these instances have occurred in just the past approximate 1.5 years.

Note: this post uses the term repeat offender to mean a business organization that has resolved more than one FCPA enforcement action regardless of which agency (the DOJ or SEC) brought the enforcement action; regardless of the form of resolution (plea agreement, NPA, DPA, administrative order, etc.) and regardless of whether the charges or findings were anti-bribery violations vs. books and records and internal controls violations in connection with foreign bribery issues). 

Stryker

Halliburton

Biomet

Orthofix

Goodyear

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Marubeni

Tyco

IBM

General Electric

ABB

Lucent / Alcatel-Lucent

Aibel Group / Vetco Gray

Baker Hughes

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