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Corporate FCPA Repeat Offenders

As highlighted in this post, twelve companies have resolved FCPA enforcement actions – not once – but twice. Thus far in 2017 there have been three FCPA repeat offenders.

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 the enforcement action (plea agreement, NPA, administrative order, etc.) and regardless of the charges or findings (anti-bribery provisions vs. books and records and internal controls provisions).

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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