In the latest top ten FCPA settlements of all time, eight are from 2010 and eight also involve non-U.S. companies.
Paris-based Alcatel-Lucent is the latest addition at number seven, knocking Shell’s November 2010 Panalpina-related enforcement action off the list.
The current top ten are:
1. Siemens (Germany): $800 million in 2008.
2. KBR / Halliburton (USA): $579 million in 2009.
3. BAE (UK): $400 million in 2010.
4. Snamprogetti Netherlands B.V. / ENI S.p.A (Holland/Italy): $365 million in 2010.
5. Technip S.A. (France): $338 million in 2010.
6. Daimler AG (Germany): $185 million in 2010.
7. Alcatel-Lucent (France): $137 million in 2010.
8. Panalpina (Switzerland): $81.8 million in 2010.
9. ABB Ltd (Switzerland): $58.3 million in 2010.
10. Pride (USA): $56.1 million in 2010.
Just six months ago, the top-ten list included four older cases — all involving U.S. companies — that have now dropped off. They were Baker Hughes from 2007, Willbros from 2008, Chevron from 2007, and Titan Corporation from a distant 2005.
[Editor’s note: the most recent list is here.]
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