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Airbus shatters the FCPA top ten

Airbus SE smashed our top ten list Friday with a $2.09 billion FCPA settlement with the U.S. Department of Justice, sending it straight to number one.

Airbus becomes the third French company to sit on the current top ten list, along with Alstom at $772 million and Société Générale at $585 million.

Officially, Airbus is headquartered in the Netherlands, but it’s often referred to as a French company because the main operations are in Toulouse.

Non-U.S. companies continue to dominate the FCPA top ten, still holding nine of ten spots. The only U.S. company currently on the list is KBR / Halliburton, now ranked tenth.

Four FCPA settlements have now reached a billion dollars or more, and it takes at least $579 million to even appear in the current top ten.

Leaving the new top ten list is Teva Pharmaceutical of Israel and its $519 million resolution in 2016.

As part of Airbus’ $4 billion global settlement, it paid French prosecutor Parquet National Financier (PNF) about $2.3 billion. The DOJ agreed to credit Airbus up to $1.8 billion for amounts paid to PNF.

The aerospace giant also paid the UK Serious Fraud Office $1.09 billion.

Those were the biggest-ever French and UK anti-bribery enforcement actions.

– – – – –

Here are the ten biggest FCPA cases of all time based on penalties and disgorgement assessed in the U.S. enforcement documents.*

  1. Airbus SE (Netherlands/France): $2.09 billion in 2020.
  2. Petróleo Brasileiro S.A. – Petrobras (Brazil): $1.78 billion in 2018.
  3. Telefonaktiebolaget LM Ericsson (Sweden): $1.06 billion in 2019.
  4. Telia Company AB (Sweden): $1.01 billion in 2017.
  5. MTS (Russia): $850 million in 2019.
  6. Siemens (Germany): $800 million in 2008.
  7. VimpelCom (Netherlands): $795 million in 2016.
  8. Alstom (France): $772 million in 2014.
  9. Société Générale S.A. (France): $585 million in 2018.
  10. KBR / Halliburton (United States): $579 million in 2009.

* Odebrecht / Braskem appeared on the top ten list in late 2016 but were removed in April 2017 after the DOJ reduced their overall penalties based on “ability to pay.”

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  1. Yikes. That’s a lot of money. I always wonder though, where does the money go? What exactly do the DOJ / SFO do with it? Yes a proportion will go into the investigation costs, but only a small percentage compared to the hugely significant fines. And what is the duty of care of these departments/offices to do good with the money? I feel like something good should always come out of something bad, so it would be wonderful if the money was put to actual decent purposes. Can anyone enlighten me? Thanks 🙂

  2. Rachael brings up a very good point. In many cases these fines don’t seem to change the behavior of the companies committing the crimes (sorry, allegedly committing the crimes). Yes, they will tell you that “they have learnt from the experience and they plan to change”, but they don’t. I read a 1968 article by Albert Z. Carr recently, titled “Is Business Bluffing Ethical? It’s a Harvard Business Review Story that can be found here:

    The sad fact is, if you read this story and recognize what is going on today, you come to the realization that nothing has changed since 1968. Companies are still playing the “game” and they have involved us all as unwitting and naïve players.

    The one good thing that has come from the Airbus example is that they have identified the titles of some of the internal staff involved, as well as the airlines that may have been influenced.

    The authorities in the countries where the airlines are located are now expanding the investigation. That is good, so long as there is some accountability in the end.

    If we look back at some older cases, such as the BHP Billiton FCPA case, the titles of the individuals who were actually involved in the wrong doing are not identified. Moreover, we heard nothing about additional investigations that may have been conducted in the countries mentioned in the settlement order. We don’t know “what happened”.

    Certainly, the more recent settlements, including Airbus, give us a better understanding of outcomes. It’s not perfect, but it is better.

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