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Editors

Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Bill Steinman
Contributing Editor

Corporate Enforcement Since 2006

Yesterday we posted our 2011 FCPA enforcement index. Today we look at corporate enforcement for the years from 2006.

Here goes:

In 2011, 15 companies paid $508.6 million in criminal and civil penalties, and in disgorgement and interest.

In 2010, 23 companies paid $1.8 billion.

In 2009, 11 companies paid $644 million.

In 2008, 11 companies paid $890.

In 2007, 15 companies paid $128 million.

And in 2006, 4 companies paid $86.25 million.

Here’s a breakdown (our first) for 2007 and 2006.

For 2007:

Aibel — $4.2 million

Baker Hughes — $44 million

Bristow Group — nil

Chevron — $28 million

Delta Pine — $300,000

Dow Chemical — $325,000

El Paso Corporation — $2.25 million

Immucor — nil

Ingersoll-Rand — $4.2 million

Lucent — $1.5 million

Omega Advisers — $500,000

Paradigm — $1 million

Textron — $3.5 million

Vetco Gray — $26 million

York — $12 million

And for 2006:

Oil States — nil

Schnitzer Steel — $15.25 million

Statoil — $21 million

Tyco — $50 million (plus $1 disgorgement)*

*Most of the charges against Tyco were for securities law violations other than FCPA offenses. The final judgment didn’t allocate the penalties.

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