With its $398 million enforcement action Wednesday, Total S.A. has landed fourth on our list of the Top 10 FCPA cases of all time.
Nine of the biggest cases involve non-U.S. companies, and three of the Top 10 are now French companies.
Dropping off the list is Panalpina of Switzerland.
This is the first change to the Top 10 list since December 2011.
Here are the current Top 10 FCPA cases* of all time:
1. Siemens (Germany): $800 million in 2008.
2. KBR / Halliburton (USA): $579 million in 2009.
3. BAE (UK): $400 million in 2010.
4. Total S.A. (France) $398 million in 2013.
5. Snamprogetti Netherlands B.V. / ENI S.p.A (Holland/Italy): $365 million in 2010.
6. Technip S.A. (France): $338 million in 2010.
7. JGC Corporation (Japan) $218.8 million in 2011.
8. Daimler AG (Germany): $185 million in 2010.
9. Alcatel-Lucent (France): $137 million in 2010.
10. Magyar Telekom / Deutsche Telekom (Hungary /Germany): $95 million in 2011.
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*An individual, Jeffrey Tesler of the U.K., agreed to an FCPA-related forfeiture of $149 million in 2011.
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