Since the start of 2008, 58 companies (by our count) have settled FCPA-related enforcement actions with the DOJ or SEC or both. Together they paid $3.74 billion in penalties, disgorgement, and interest — an average of $64.5 million per enforcement action.
The yearly numbers break down this way:
In 2011 year-to-date, 13 companies have paid $405.6 million, for an average settlement of $31.2 million (including $28 million paid in an FCPA settlement that also included a price-fixing count).
In 2010, 23 companies paid $1.8 billion for an average settlement of $78 million.
In 2009, 11 companies paid $644 million, averaging $58.5 million per corporate FCPA enforcement action.
In 2008, 11 companies paid $890 million for an average of $80 million. Excluding Siemens’ $800 million resolution, 10 companies paid $90 million for an average of $9 million (Siemens is included in the $64.5 million overall average for the period in question).
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Managing compliance risks. More than 100 companies — many of them global leaders — took part in the Anti-Corruption Compliance Program Benchmarking Survey. The findings (available here) should help those seeking to assess or improve their compliance programs.