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More False And Misleading Information From The FCPA Blog


The FCPA Blog recently published this post titled “These are the Biggest FCPA Cases for Each of the Past Ten Years.”

Like other information on the FCPA Blog, the post contains false and misleading information.

The FCPA Blog post highlights “settlement amounts per data from FCPA Blog+” [a paid service of the entity that publishes the FCPA Blog] and the settlement amounts include “all criminal and civil penalties imposed on the highest-level entity and all related entities named in the enforcement action documents, as well as special assessments, forfeiture, disgorgement, and prejudgment interest, without regard to where the DOJ and / or SEC said the money would or could be paid.”

However, the dictionary (and practical) definition of “imposed” means to establish or bring about by force and it is quite clear (very simply clear from reading FCPA resolution documents) that many of the settlement amounts highlighted by the FCPA Blog were never actually “imposed” by the DOJ/SEC (the only law enforcement agencies that enforce the FCPA) on the companies listed.

If the FCPA Blog wants to call these global settlement amounts or more accurately global settlement amounts that law enforcement agencies could theoretically have imposed (in their own estimation) fine, do that.

But don’t call these settlement amounts in “FCPA cases” or “FCPA resolutions” because they simply aren’t.

As highlighted in the below chart, this is no trivial matter.

The difference between the FCPA Blog’s settlement amount assertions and actual FCPA settlement amounts is $4.3 billion difference over just a ten year period.


FCPA Blog Assertion Actual FCPA Settlement Amount


2022 Glencore – $700 million Glencore – $443 million
2021 Deutsche Bank – $123 million Deutsche Bank – $123 million
2020 Goldman Sachs – $3.3 billion Goldman Sachs – $1.66 billion
2019 Ericsson – $1.06 billion Ericsson – $1.06 billion
2018 Petrobras – $1.78 billion Societe General – $293 million
2017 Telia – $1.01 billion Telia – $483 million
2016 Vimpelcom – $795 million Vimpelcom – $398 million
2015 BHP Billiton – $25 million BHP Billiton – $25 million
2014 Alstom – $772 million Alstom – $772 million
2013 Total – $398 million Total – $398 million

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