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Harry Cassin
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Corporate Enforcement Countdown

In a post earlier this week, we added up the number of enforcement actions since 2005 against corporations and individuals. We’re searching for clues about how enforcement decisions are made, and whether corporate settlements might be replacing individual prosecutions.

We eventually found 83 corporate actions and 106 individual prosecutions since 2005. But that didn’t tell us much. We needed to know who the individuals worked for. And that, in turn, would tell us how many of the corporations settled cases in which none of their personnel were charged.

The results are now in. Of the 83 corporate enforcement actions from 2005 through today, 63 of them involved a total of 37 companies that had no individuals (employees or agents) charged. Said another way, of the 57 companies that make up the 83 corporate enforcement actions since 2005, 37 of them had no related individuals charged. 

Of those 37, two cases could be debated: El Paso settled an enforcement action based on bribes paid by Oscar Wyatt, founder of Coastal Corporation, which El Paso acquired. Similarly, Halliburton settled an action based on bribes paid or arranged by Jack Stanley when he was head of KBR, which was acquired by Halliburton. But strictly speaking, no one from either El Paso or Halliburton faced prosecution, so we’re counting them among the 37 corporate-only actions.

Overall, the numbers mean that since 2005, more than sixty percent of the companies that settled FCPA enforcement actions have not yet had individual employees or agents who were charged. 

The 37 companies that we think have settled enforcement actions (for themselves and their subsidiaries) since 2005, in which none of their employees or agents have yet faced charges, are listed below. Before getting to the list, however, we want to thank Qi Chen, a student at the Chicago-Kent Law School, for his countless hours of research. Simply numbering enforcement actions and determining how many companies and individuals have been involved is a big-league challenge. The DOJ and SEC don’t publish master lists or always coordinate their enforcement actions, many of which involve subsidiaries and affiliates. That’s why no two independent tabulations are ever the same. So Qi did heroic work here. His methodology was directed by Professor Andy Spalding, who also supervised the research. We’re grateful to him as well. But any errors in the final list are ours alone.

The 37 companies that settled enforcement actions since 2005, in which none of their personnel have yet been charged, are:

 AB Volvo

AGA Medical Corp


Aibel Group Ltd.

Akzo Nobel N.V.

Avery Dennison Corp.

BAE Systems PLC

Bristow Group Inc.

Chevron Corp.

Con-way Inc.

Daimler A.G.

Delta & Pine Land Co.

DPC (Tianjin) Co. Ltd.

El Paso Corp.

Faro Technologies

Fiat S.p.A., et al.

Flowserve Corp.

Halliburton Co.

Helmerich & Payne, Inc


Ingersoll-Rand Co. Ltd.

ITT Corp

Latin Node, Inc.

Lucent Technologies Inc.

Micrus Corp.

Natco Group

Novo Nordisk A/S

Oil States Int’l, Inc.

Paradigm B.V.

Siemens Aktiengesellschaft

Statoil ASA

Technip S.A.

Textron Inc.

The Dow Chemical co.

Tyco Int’l Ltd.

Veraz Networks, Inc

Westinghouse Air Brake

York International Corp.

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