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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

Teva ranks fourth on our new Top Ten list

Teva Pharmaceutical’s $519 million resolution Thursday landed fourth on our list of the ten biggest FCPA cases of all time. It’s the first time an Israeli company has appeared in the top ten.

The top ten list has now changed three times in 2016. Och-Ziff also joined the list in September with a $412 million resolution. And in February, VimpelCom’s $397.6 million settlement cracked the top ten.

Dropping off the list Thursday was Technip SA of France. It paid $338 million in 2010 for FCPA violations.

The ten biggest FCPA cases involved financial penalties of $5.36 billion, or an average of $536 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. Teva Pharmaceutical (Israel): $519 million in 2016.

5. Och-Ziff (USA): $412 million in 2016.

6. BAE (UK): $400 million in 2010.

7. Total SA (France) $398 million in 2013.

8. VimpelCom (Holland) $397.6 million in 2016.

9. Alcoa (U.S.) $384 million in 2014.

10. Snamprogetti Netherlands B.V. / ENI S.p.A (Holland/Italy): $365 million in 2010.


Richard L. Cassin is the publisher and editor of the FCPA Blog.

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  1. And then….. there was Odebrecht moving all other fine payers down by one (as well as by a wide margin)

  2. Sorry. Odebracht – Baskem don't make the Top Ten FCPA list. Their separate global settlements are apparently very large. But their FCPA settlements aren't. We'll explain more in a post later.

  3. Dear Richard,

    Two questions:
    a. I'm interested in your explanation of why the total criminal penalty is not related to a FCPA violation.
    b. How and when is the cost of the compliance program calculated?

    I guess your answer to Odebrecht applies to Braskem S.A as well.

    Many thanks!
    Roberto de Michele

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