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Harry Cassin
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Andy Spalding
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Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
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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

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

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