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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

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Our Top Ten List didn’t change in 2015 (but here’s when it did change)

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.

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