- FCPA Professor - http://fcpaprofessor.com -

The Top Ten List Of Corporate FCPA Settlements

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

This post highlights the top ten corporate FCPA settlements of all-time.

It seems odd saying this, but the list (unlike other lists) only includes enforcement actions where the corporate defendant was charged with or found to be in violation of the FCPA’s provisions (not other laws). In addition, the list highlights net FCPA settlement amounts after consistently accounting for (unlike other lists [1]) certain credits or deductions in several enforcement actions involving foreign companies.

1. MTS

2. Siemens

3. Alstom

4. KBR/Halliburton 

5. Teva Phrama

6. Telia

7. Och-Ziff

8. Total

9. VimpelCom

10. Alcoa