The biggest FCPA settlement in 2015 was BHP Billiton. It paid $25 million to the SEC to settle Olympics-related FCPA offenses. The case fell far short of the Top Ten List, missing a tenth place finish by a whopping $160 million.
In most years, the Top Ten changes.
Here’s what’s happened in prior years:
- In 2014, two enforcement actions — Alstom and Alcoa — landed in the Top Ten.
- In 2013, two actions — Total SA and Weatherford — made the Top Ten.
- In 2012, the biggest FCPA case was Pfizer. It paid $60 million — not enough for a Top Ten ranking.
- In 2011, three cases made it into the Top Ten — JGC, Magyar Telekom, and Johnson & Johnson.
- The Top Ten List was transformed in 2010. Eight companies made it — BAE, Snamprogetti/ENI, Technip, Daimler, Alcatel-Lucent, Panalpina, ABB, and Pride.
- In 2009, the biggest settlement was Kellogg Brown & Root LLC /Halliburton (Nigeria) at $579 million, still third in the current Top Ten.
- In 2008, Siemens paid $800 million — the biggest FCPA enforcement action ever and the oldest entry in the Top Ten.
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.