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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
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Richard Bistrong
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Eric Carlson
Contributing Editor

Alcoa disgorgement is third biggest in FCPA history

As part of its $354 million settlement this week, Alcoa agreed to pay the third biggest disgorgement in FCPA history — $161 million.

What is disgorgement? It’s a remedy, according to our contributing editor Marc Alain Bohn, authorized by the Securities Exchange Act of 1934 that’s ‘used to deprive wrong-doers of their ill-gotten gains and deter violations of federal securities law.’

The FCPA was enacted in late 1977. But disgorgement didn’t appear in an FCPA enforcement action until 2004, when ABB Ltd disgorged $5.9 million to resolve books and records and internal controls offenses.

Since then the SEC has used disgorgement in more than three-quarters of its FCPA-related enforcement actions.

Here are the current top ten FCPA-related corporate disgorgements (including prejudgment interest):

1. Siemens $350 million in 2008

2. KBR  $177 million in 2009

3. Alcoa $161 million in 2014

4. Total S.A. $153 million in 2013

5. Snamprogetti $125 million in 2010

6. Technip $98 million in 2010

7. Daimler $91.4 million in 2010

8. Pfizer $45.2 million in 2012

9. Alcatel-Lucent $45 million in 2010

10. Chevron $25 million in 2007

For comparison, here’s our current list of the top ten FCPA enforcement actions of all time.


Richard L. Cassin is the Publisher and Editor of the FCPA Blog. He can be contacted here.

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