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
- 2018 ($7.8 million enforcement action concerning conduct in India, China, and Kuwait)
- 2013 ($13.2 million enforcement action concerning conduct in Mexico, Poland, Romania, Argentina, and Greece)
Halliburton
- 2017 ($29.2 million enforcement action concerning conduct in Angola)
- 2009 ($177 million enforcement action concerning conduct in Nigeria)
Biomet
- 2017 ($30.4 million enforcement action concerning conduct in Brazil and Mexico)
- 2012 ($22.8 million enforcement action concerning conduct in Brazil, Argentina and China)
Orthofix
- 2017 ($6 million enforcement action concerning conduct in Brazil)
- 2012 ($7.4 million enforcement action concerning conduct in Mexico)
Goodyear
- 2015 ($16 million enforcement action concerning conduct in Kenya and Angola)
- 1989 ($250,000 enforcement action concerning conduct in Iraq)
Marubeni
- 2014 ($88 million enforcement action concerning conduct in Indonesia)
- 2012 ($55 million enforcement action concerning conduct in Nigeria)
Tyco
- 2012 ($26.8 million enforcement action concerning conduct in China, India, Thailand, Laos, Indonesia, Bosnia, Croatia, Serbia, Slovenia, Slovakia, Iran, Saudia Arabia, Libya, Syria, the United Arab Emirates, Mauritania, Congo, Niger, Madagascar, Turkey, Malaysia, Egypt, and Poland)
- 2006 ($50 million enforcement action concerning conduct in Brazil)(Note: this was largely an accounting fraud enforcement action and the FCPA prong was a relatively minor component).
IBM
- 2011 ($10 million enforcement action concerning conduct in South Korea and China)
- 2000 (cease and desist order concerning conduct in Argentina)
General Electric
- 2010 ($23.4 million enforcement action concerning conduct in Iraq)
- 1992 ($9.5 million enforcement action concerning conduct in Israel)(Note: FCPA as well as related charges)
ABB
- 2010 ($58.3 million enforcement action concerning conduct in Mexico and Iraq)
- 2004 ($16.4 million enforcement action concerning conduct in Nigeria, Angola and Kazakhstan)
Lucent / Alcatel-Lucent
- 2010 ($137.4 million enforcement action concerning conduct in Costa Rica, Honduras, Malaysia, Taiwan, Kenya, Nigeria, Bangladesh, Ecuador, Nicaragua, Angola, the Ivory Coast, Burkina Faso, Uganda, and Mali)
- 2007 ($2.5 million enforcement action concerning conduct in China)
Aibel Group / Vetco Gray
- 2008 ($4.2 million enforcement action concerning conduct in Nigeria)
- 2007 ($26 million enforcement action concerning conduct in Nigeria)
Baker Hughes
- 2007 ($44 million enforcement action concerning conduct in Kazakhstan, Nigeria, Angola, Indonesia, Russia, Uzbekistan)
- 2001 (cease and desist order concerning conduct in Indonesia, India and Brazil)
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