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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
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

Is a December enforcement surprise on the way?

For most of us, December means giant year-end bonuses, moving to bigger houses, and getaways to the Turks and Caicos. No, that’s not true.

But it is true that for the FCPA, December can mean big news.

Three of the top ten FCPA settlements happened in past years during December.

Will there be a mega-settlement this month?


Some investigations we’ve been watching that could be ripe for resolution — and may crack the top ten —  include Avon, Alcoa, Weatherford, Total, and Hewlett Packard. Pharmas are on the watch list, and some medical device makers too. So is Alstom. Wal-Mart? Maybe next year.

The three December top tenners now are Magyar Telekom (December 2011), Alcatel Lucent (December 2008), and Siemens (December 2008).

Siemens still wears the crown for the biggest FCPA enforcement action of all time.

*     *     *

Here’s our current top ten list.

It hasn’t changed since — you guessed it — December last year:

1. Siemens (Germany): $800 million in 2008.

2. KBR / Halliburton (USA): $579 million in 2009.

3. BAE (UK): $400 million in 2010.

4. Snamprogetti Netherlands B.V. / ENI S.p.A (Holland/Italy): $365 million in 2010.

5. Technip S.A. (France): $338 million in 2010.

6. JGC Corporation (Japan) $218.8 million in 2011.

7. Daimler AG (Germany): $185 million in 2010.

8. Alcatel-Lucent (France): $137 million in 2010.

9. Magyar Telekom / Deutsche Telekom (Hungary /Germany): $95 million in 2011.

10. Panalpina (Switzerland): $81.8 million in 2010.

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