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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

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Country Count for the Corporate Investigations List (January 2017)

The volunteer researcher who compiles the FCPA Blog’s Corporate Investigations List has again tabulated all of the countries mentioned or reported in connection with the 81 companies included on the latest list.

The country count is accurate through December 31, 2016.

For the first time since we started publishing the Country Count two years ago, China doesn’t top the list.

This time its Brazil with 19 mentions in connection with ongoing FCPA investigations.

China is next with 16 mentions, then Iraq with 8 and Kazakhstan with 6.

India had 5 mentions. That includes Mondelēz, which settled an FCPA enforcement action after December 31, 2016, and had mentioned India in its investigation disclosure.

Country names were mentioned a total of 130 times in the 81 pending investigations.

Countries mentioned most were:

Brazil – 19

China – 17

Iraq – 8

Kazakhstan – 6

India – 5

Angola – 4

Nigeria – 4

South Africa – 4

Uzbekistan – 4

Azerbaijan – 3

Kuwait – 3

Syria – 3

There were also 14 countries with two disclosed investigations and 28 countries with one disclosed investigation.


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

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  1. There has to be a mistake here. Mexico is involved in several investigations and is almost certainly in the top five.

  2. It appears things haven't changed much over the years on Corporation Investigations. Would you be kind in informing me what other 14 countries with two disclosed investigations and 28 countries with one disclosed investigation?
    Thank you
    Subash Murray

  3. Note to Mr. Garcia — The numbers are correct, based on the guidelines we use for reporting corporate investigations, and based on the actual self disclosures by the companies involved. Not all companies self disclose pending FCPA investigations, and not all disclosures by the companies include information about the countries that might be involved. I hope this helps. — rlc

  4. Here's a note from our researcher in response to Mr. Garcia's comment: "For your reference there were only two know FCPA disclosures involving Mexico – Walmart and Zimmer Biomet (which just settled). So while the commenter's perception is right that Mexico is highly corrupt…there just aren't any disclosed issues relating to Mexico. We looked at the previous statistics and Mexico was 3 (Grifols just received a declination). Teva had just recently disclosed issues in Mexico, but they settled last quarter so the Mexico disclosure didn’t make the final list."

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