The 40 biggest Foreign Corrupt Practices Act resolutions of all time now have penalties totaling over $17.1 billion. Put another way, that’s more money than the GDPs of Belize, Somalia, the Seychelles, and Kyrgyzstan combined.
The newest company on the list is Airbus, which smashed our top ten list in January with a $2.09 billion FCPA settlement with the U.S. Department of Justice.
Nine companies on the top 40 come from the United States and six from France.
Four companies are from Germany, and three each from Switzerland, Japan, Brazil, the Netherlands, and the United Kingdom.
The two Swedish companies on the list — Ericsson and Telia — both appear in the top ten.
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 35th. Its other FCPA settlement in 2012 for $54.6 million missed the current top 40 by six places.
With the addition of Airbus, Legg Mason dropped off the list with its $64.2 million settlement in 2018.
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.
A detailed explanation of how we calculate FCPA settlement amounts is here.
View the full list of companies on FCPA Blog+