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Complete Rubbish

rubbish

The FCPA Blog, one of the leading sources of misinformation in the Foreign Corrupt Practices Act space, is at it again.

This post asserts that with the recent J&F enforcement action (see here for the prior post) “2020 has officially become the largest year ever for FCPA settlements, with resolutions worth $2.94 billion.”

As highlighted below, the assertion is complete rubbish.

As set forth below, thus far in 2020 FCPA settlement amounts have totaled approximately $1.0 billion – a far cry from the $2.94 billion the FCPA Blog asserts.

Airbus

See here and here for prior posts.

$294 million DOJ settlement

Cardinal Health

See here and here for prior posts.

$8.8 million SEC settlement

Eni

See here and here for prior posts.

$24.5 million SEC settlement

Novartis

See here and here for prior posts.

$346.7 million settlement (DOJ – $233.9 million / SEC $112.8 million)

Alexion

See here and here for prior posts.

$21.5 million SEC settlement.

World Acceptance Corp.

See here and here for prior posts.

$21.7 million SEC settlement

Herbalife

See here and here for prior posts.

$123 million settlement (DOJ – $55.7 million / SEC 67.3 million)

Sargeant Marine

See here and here for prior posts.

$16.6 million DOJ settlement

J&F

See here for the prior post.

$155 million settlement (DOJ – $128.2 million / SEC $26.8 million)

Year to date FCPA settlement amounts = $1.01 billion.

Set forth below is where 2020 YTD falls in terms of the largest yearly FCPA settlement amounts in FCPA history.

2019

  • $2.65 billion in settlement amounts

2016

  • $2.4 billion in settlement amounts

2014

  • $1.6 billion in settlement amounts

2010

  • $1.4 billion in settlement amounts

2017

  • $1.1 billion in settlement amounts

2020 (YTD)

  • $1.0 billion in settlement amounts

What is funny about the FCPA’s blog assertion that “2020 has officially become the largest year ever for FCPA settlements, with resolutions worth $2.94 billion” is that the post was a teaser for its FCPA Blog+ paid subscription service “the same tool [the FCPA Blog] used to research [its] post.”

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