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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

Correction: H-P disgorgement is 11th biggest

Hewlett-Packard’s $108 million settlement this week didn’t quite make our list of the top ten FCPA cases of all time. But with a disgorgement to the SEC of $26.4 million, H-P landed eleventh on the list of the biggest FCPA disgorgements.

(An earlier version of this post incorrectly said H-P’s disgorgement was the tenth biggest. We’re sorry for the error and thank a sharp-eyed reader for the correction.)

Disgorgement, according to contributing editor Marc Alain Bohn, is a remedy 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.”

Disgorgement first appeared in an FCPA enforcement action in 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:

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. Archer Daniels Midland $36.5 million in 2013

11. Hewlett-Packard $26.4 million in 2014

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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