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.