Monday’s $772 million DOJ enforcement action against Alstom SA and several subsidiaries landed second on our list of the top ten FCPA cases of all time.
The addition of Paris-based Alstom means three of the top ten FCPA cases now involve French companies. Total SA is number five and Technip is number eight. No other country appears more than twice in the top ten.
Eight companies in the top ten are non-U.S. firms.
The biggest FCPA enforcement action is still Siemens’ $800 million settlement from 2008.
The top ten cases involved financial penalties of $4.4 billion, or an average of $440 million.
Dropping off the list today is Weatherford International’s $152.6 million resolution in 2013.
Here are the current top ten FCPA enforcement actions of all time:
1. Siemens (Germany): $800 million in 2008.
2. Alstom (France): $772 million in 2014.
3. KBR / Halliburton (USA): $579 million in 2009.
4. BAE (UK): $400 million in 2010.
5. Total SA (France) $398 million in 2013.
6. Alcoa (U.S.) $384 million in 2014.
7. Snamprogetti Netherlands B.V. / ENI S.p.A (Holland/Italy): $365 million in 2010.
8. Technip SA (France): $338 million in 2010.
9. JGC Corporation (Japan) $218.8 million in 2011.
10. Daimler AG (Germany): $185 million in 2010.
Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.