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.