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It Is Absolute BullSh*t To Assert That “Companies Are Now Paying An Average Of Half A Billion Dollars To Settle FCPA Enforcement Actions”


This FCPA Blog post asserts “Companies are now paying an average of half a billion dollars to settle FCPA enforcement actions.”

This is absolute bullsh*t.

More FCPA fake news.

Set forth below are the actual FCPA settlement amounts from 2020 corporate enforcement actions.

  • Goldman Sachs ($1.6 billion)
  • Novartis ($347 million)
  • Airbus ($294 million)
  • J&F ($155 million)
  • Herbalife ($123 million)
  • Vitol ($90 million)
  • Eni ($24.5 million)
  • World Acceptance ($21.7 million)
  • Alexion ($21.5 million)
  • Beam ($19.6 million)
  • Sargeant Marine ($16.6 million)
  • Cardinal Health ($8.8 million)

Thus, the average corporate FCPA settlement amount in 2020 was approximately $232 million. Averages of course (particularly when there were only 12 corporate enforcement actions in 2020) can be skewed by outliners (such as the $1.6 billion Goldman FCPA settlement).

Thus, the median corporate FCPA settlement in 2020 was approximately $65 million.

It’s funny that the FCPA Blog’s post containing the false and misleading numbers was titled “Five Numbers That Show Just How Big The FCPA Industry Has Become.”

One thing that shows “just how big the FCPA industry has become” is that a for-profit website that sells FCPA products and services and has approximately 15 blinking and flashing ads from FCPA Inc. participants juices its numbers and publishes false and misleading information to make FCPA enforcement appear more robust and draconian than it actually is.

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