Thursday’s $397.6 million enforcement action against VimpelCom Ltd. and its Uzbek unit landed in the sixth spot on our list of the top ten FCPA cases of all time.
It was the first change in our top ten list since Alstom joined in the number two position in December 2014.
Dropping off the list Thursday was Daimler AG’s $185 million resolution in 2010.
Eight companies in the top ten are non-U.S. firms.
Three of the top ten FCPA cases involve French companies. No other country appears more than twice in the top ten.
The biggest FCPA enforcement action is still Siemens’ $800 million settlement from 2008.
The top ten cases involved financial penalties of $4.65 billion, or an average of $465 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. BAE (UK): $400 million in 2010.
5. Total SA (France) $398 million in 2013.
6. VimpelCom (Holland) $397.6 million in 2016.
7. Alcoa (U.S.) $384 million in 2014.
8. Snamprogetti Netherlands B.V. / ENI S.p.A (Holland/Italy): $365 million in 2010.
9. Technip SA (France): $338 million in 2010.
10. JGC Corporation (Japan) $218.8 million in 2011.
Richard L. Cassin is the publisher and editor of the FCPA Blog. He can be contacted here.
I have been enjoying this blog over the past few years and am a diligent follower. That said, I struggle with the “Top Ten list.” This list only ranks enforcement actions that have resulted in high monetary penalties. But I am not sure that the highest sum equals the highest impact. I’d be really interested in a list that ranks the highest impact cases—those which have resulted in corporate behavioral change within the company that was the subject of the action, or changes in the industry or the like. I realize that such an assessment is a difficult one, but I think it would be a great one to see.
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