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Harry Cassin
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The FCPA Top 40 surges past $17 billion

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+

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  1. I would suggest that it is time to adjust this table and to reassess the amounts taking into account inflation and PPPs. Certain penalties like Siemens and KBR are not quite old and if we want the comparison to make sense you need to have the same baseline.

  2. Good assessment Harry!

    I think we need to reflect on the fact that the size of these penalties does not necessarily indicate that the world is becoming more corrupt, but the quality and coordination of the investigations is getting better.

    When one reviews historical cases, it is difficult to glean any detail about the violations that may have occurred.

    If we take a look at the BHP Billiton matter for example, there was considerable confusion about the lessons learned from the case. As stated on Page 9 of a Debevoise & Plimpton FCPA Update (May 2015, Volume 6, Number 10), “the terms of the BHPB resolution are the product of negotiation designed to serve the immediate interests of the parties in resolving a pending matter, and not the broader interest in definitively clarifying the law.”

    Well, moving forward several years, there appears to be greater effort in providing more detail and clarifying the law. And, this seems to have been achieved through more thorough investigations and coordination with the authorities of other jurisdictions, which has resulted in higher fines.

    This is why, to some extent, I disagree with the argument that the Corruption Perception Index (CPI) is upside down. I would fully expect that the regulatory authorities in countries perceived to be “clean” or “very clean” (e.g. Singapore, Germany, Switzerland, Sweden etc.) would be more aggressive in pursuing their own companies, or “National Champions”. Therefore, we probably shouldn’t be surprised by the increased number of corruption cases being pursued in these jurisdictions.

    I’m more concerned about the activities of companies, or “National Champions”, in countries that are not scoring well on the CPI, or getting worse (e.g. Australia). These are the countries that should be more aggressive in shining the light on corruption.

    Basically, they don’t know what they don’t know. Or, they do know and are concerned about the potential reputational and economical damage. I guess it’s safer to bury one’s head.

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