A reader asked if there have been any FCPA cases involving small bribes — say under $1 million. The answer is: Yes, lots of them.
Here’s a rundown of some of those “small bribe” enforcement actions.
The NCH Corporation declination with disgorgement last year was for a bribe of $44,545.
The bribe to PDVSA in US v Roberto Enrique Rinco Fernandez (2016) was $790,000.
The bribe in the Ralph Lauren Corp enforcement action (2013) was $538,000.
The bribe in the BizJet enforcement action (2011) was stated to be $565,000.
The bribe in the Tyco enforcement action (2012) was $488,479.
The bribe in the Orthofix enforcement action (2012) was $300,000.
The bribe in US v Data Systems & Solutions (2012) was $485,000.
The bribe in the Aon enforcement action (2011) was $865,000.
The value of the bribe in US v Tenaris (20111) was stated as “more than $32,140.”
The bribe in the Comverse Technology enforcement action (2011) was $536,000.
The bribe in Tyson Foods (2011) was about $350,000.
The bribe in the LatiNode cases was $545,039.
The bribe in Transocean (2010) was about $90,000.
The bribe in Pride International (2010) was about $800,000.
The bribe in Noble Corp. (2010) was $74,000.
The bribe in Universal Leaf (2010) was about $697,800.
The bribe in AGCO (2009) was about $553,000.
The bribe in Helmerich & Payne was about $173,000.
The bribe in US v Martin Eric Self (2008) was $70,350.
The bribe in Flowserve (2008) was $778,409.
The bribe in Westinghouse Air Brake Technologies (2008) was $170,542.
And so on . . . . .
The list isn’t exclusive.
Richard L. Cassin is the publisher and editor of the FCPA Blog.