Enforcement At The Century’s Dawn

In Tuesday’s post, we looked at corporate FCPA enforcement since 2006. Today we’re going back further.

The years 2000 through 2005 are already ancient FCPA history. There were just fifteen cases and all but two penalties were under $5 million.

Speaking of penalties, disgorgement first appeared in an FCPA case in 2004. ABB Ltd paid the SEC $5.9 million in disgorged profits to settle civil antibribery, books-and-records, and internal-controls offenses.

Here’s the record:

In 2005, 5 companies paid $36.3 million.

DPC — $4.8 million

Invision — $1.1 million

Micrus — $450,000

Monsanto — $1.5 million

Titan — $28.5 million

In 2004, 3 companies paid $16.4 million.

ABB — $15.9 million

B.J. Services — nil

Schering-Plough — $500,000

In 2003, 0 companies paid nil.

In 2002, 2 companies paid $2.6 million.

BellSouth — $150,000

Syncor — $2.5 million

In 2001, 4 companies paid $175,000.

American Bank Note Holographics — $75,000

Baker Hughes — nil

Chiquita Brands International — $100,000

KPMG Siddharta Siddharta & Harsono — nil

In 2000, 1 company paid $300,000.

IBM — $300,000