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New List: The FCPA Top 40

Here’s the FCPA Blog’s list of the 40 biggest Foreign Corrupt Practices Act resolutions of all time.

What stands out?

There’s a surprisingly wide geographical distribution of the companies in the top 40. Ten come from the United States and five from France. Four companies are from Germany, followed by three each from Switzerland, Japan, Brazil, the Netherlands, and the United Kingdom.

Two companies come from Sweden. And one each from Israel, Singapore, Italy, Hungary, South Korea, and Russia.

One company (and a successor) appears on the list twice. Technip SA made the top 40 for an FCPA enforcement action in 2010 and again — as TechnipFMC plc — for another FCPA case in 2019.

(Marubeni Corporation almost made the top 40 twice. Its $88 million FCPA resolution in 2014 ranks 34th. Its other FCPA settlement in 2012 for $54.6 million missed the current top 40 by five places.)

The most active years for top 40 FCPA enforcement actions have been 2016 with seven, followed by 2010 and 2019 (so far) with six each.

View the full list here.

A couple of notes about this list.

When two companies appear at the same entry, it means they were jointly liable, or both were named as parties in the same or parallel U.S. enforcement actions.

The values for the resolutions were taken from the DOJ and SEC enforcement documents and reflect the actual assessments by those agencies of criminal and civil penalties and disgorgement, without regard to where the DOJ and SEC said the money would or could be paid.

In the case of Odebrecht’s FCPA settlement, it wasn’t clear where on the list it should appear so we left it off.

Here’s why. In 2016 the DOJ assessed total criminal penalties against Odebrecht of $2.6 billion, with ten percent of that payable in the United States and the rest payable to authorities in Brazil and Switzerland. Soon after the FCPA resolution, Odebrecht said its ability to pay had been impaired because of lost business. The DOJ then reduced the U.S. share of the criminal penalties down from $260 million to $93 million. After that, however, Odebrecht declared bankruptcy, throwing into doubt how much of the global criminal penalties, if any, the company will pay in any country.

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  1. Dick, this is a great list. Well done in gathering it! One of the things that jumps out immediately is the very small number of U.S. issuers on the list, particularly as one gets closer to the top. Though I remain convinced that the FCPA is not used as a trade weapon (at least in most situations), it is certainly a stark reminder of the compliance demands that many foreign companies are not prepared for when becoming issues!

    • Definitely agree.

  2. Dick, Harry et al, I’d love to see your subjective list of top-however-many most impactful settlements (or opinion releases!). It would make great reading, no doubt!

  3. Bravo Dick and Harry. Outstanding.

    Beyond the stand-out issues highlighted (re geography and economics), I wonder if there are common connectors among these in respect of leadership and various other aspects of decision-making and human-factor issues? If those data points can be identified and studied, I expect there will be a lot of meaningful lessons to be extrapolated for senior executives and their boards, as well as E&C professionals and regulators.

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