Kaplan’s Top Ten Corporate Criminal Fines

On his great Conflict of Interest Blog, Jeff Kaplan posted the ten biggest U.S. corporate criminal fines of all time.

They add up to more than $6.75 billion.

What’s striking, Jeff says, ‘is that fully half of the ten largest federal corporate criminal fines in history were imposed or agreed to in 2012.’

But as Jeff said in his post, the ‘list is based only on federal corporate criminal fines. Many of the cases here also involved federal or state criminal forfeitures, regulatory or civil penalties, and/or criminal (as well as other) fines or judgments imposed in other countries  – none of which were included in developing this list.’

Two FCPA cases are named — Siemens and KBR / Halliburton. They account for $852 million. (Jeff’s numbers include only DOJ criminal fines and not SEC civil penalties and disgorgements).

On his list of the top corporate criminal fines of all time are:

1.  BP – $1.256 billion (environmental and related offenses) (2012)

2.  Pfizer – $1.2 billion (marketing offenses) (2009)

3.  GlaxoSmithKline – $956 million (marketing offenses) (2012)

4.  Eli Lilly – $515 million (marketing offenses) (2009)

5.  AU Optronics – $500 million (antitrust) (2012)

6.  Abbott Laboratories – $500 million (marketing offenses) (2012)

7.  Hoffman-LaRoche – $500 million (antitrust) (1999)

8.  Yakazi – $470 million (antitrust) (2012)

9.  Siemens – $450 million (FCPA) (2009)

10. Halliburton/KBR – $402 million (FCPA) (2008)

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Jeff Kaplan’s full post is here.

Our top ten FCPA enforcement actions are here.

And our top ten FCPA disgorgements are here.