Everybody, it seems, likes “Top Ten” lists.
This post highlights the top ten corporate FCPA settlements of all-time.
It seems odd saying this, but the list (unlike other lists) only includes enforcement actions where the corporate defendant was charged with or found to be in violation of the FCPA’s provisions (not other laws). In addition, the list highlights net FCPA settlement amounts actually secured by U.S. law enforcement after consistently accounting for (unlike other lists) certain credits or deductions in several enforcement actions involving foreign companies.
1. Ericsson
- 1.06 billion
- ($520 million DOJ)($540 million SEC)
- 2019
2. MTS
- $850 million
- ($750 million DOJ)($100 million SEC)
- 2019
3. Siemens
- $800 million
- ($450 million DOJ)($350 million SEC)
- 2008
4. Alstom
- $772 million
- ($772 million DOJ)
- 2014
5. KBR/Halliburton
- $579 million
- ($402 million DOJ)($177 million SEC)
- 2009
6. Teva Phrama
- $519 million
- ($283 million DOJ)($236 million SEC)
- 2016
7. Telia
- $483 million
- ($275 million DOJ)($208 million SEC)
- 2017
8. Och-Ziff
- $412 million
- ($213 million DOJ)($199 million SEC)
- 2016
9. Total
- $398 million
- ($245 million DOJ)($153 million SEC)
- 2013
10. VimpelCom
- $397.5 million
- ($230 million DOJ)($167.5 million SEC)
- 2016
