Last week’s $412 million enforcement action against Och-Ziff Capital Management Group landed fourth on our list of the ten biggest FCPA cases of all time.
It was the first change in the list since VimpelCom joined the top ten in February this year.
Dropping off the list last week was JGC Corporation (Japan). It had a $218.8 million resolution in 2011.
Och-Ziff is the first U.S. company to join the top ten since Alcoa’s $384 million enforcement action in 2014.
There are now three U.S. companies in the top ten.
The ten biggest FCPA cases involved financial penalties of $4.84 billion, or an average of $484 million.
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. Och-Ziff (USA): $412 million in 2016.
5. BAE (UK): $400 million in 2010.
6. Total SA (France) $398 million in 2013.
7. VimpelCom (Holland) $397.6 million in 2016.
8. Alcoa (U.S.) $384 million in 2014.
9. Snamprogetti Netherlands B.V. / ENI S.p.A (Holland/Italy): $365 million in 2010.
10. Technip SA (France): $338 million in 2010.
Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.