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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.

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  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. Mobile TeleSystems Public Joint Stock Company (Russia): $850 million in 2019.
  6. Siemens AG (Germany): $800 million in 2008.
  7. VimpelCom Ltd. (Netherlands): $795 million in 2016.
  8. Alstom S.A. (France): $772 million in 2014.
  9. Société Générale S.A. (France): $585 million in 2018.
  10. Kellogg Brown & Root LLC  / Halliburton Company (United States): $579 million in 2009.
  11. Teva Pharmaceuticals Industries Inc. (Israel): $519 million in 2016.
  12. Keppel Offshore & Marine Ltd. (Singapore): $422 million resolution in 2017.
  13. Och-Ziff Capital Management Group LLC (United States): $412 million in 2016.
  14. BAE Sytems plc (United Kingdom):$400 million in 2010.
  15. Total SA (France): $398 million in 2013.
  16. Alcoa Inc. (United States): $384 million in 2014.
  17. Snamprogetti Netherlands B.V. / ENI S.p.A (Italy): $365 million in 2010.
  18. Technip SA (France): $338 million in 2010.
  19. TechnipFMC plc (United Kingdom): $301 million in 2019.
  20. Walmart Inc. (United States): $282.7 million in 2019.
  21. Panasonic Corporation / Panasonic Avionics Corporation (Japan): $280 million in 2018.
  22. JPMorgan Chase & Co. (United States): $264.4 million in 2016.
  23. SBM Offshore N.V. (Netherlands): $238 million in 2017.
  24. Fresenius Medical Care AG & Co. KGaA (Germany): $231.7 million in 2019.
  25. JGC Corporation (Japan): $218.8 million in 2011.
  26. Embraer SA (Brazil): $205 million in 2016.
  27. Daimler AG (Germany): $185 million in 2010.
  28. Rolls-Royce plc (United Kingdom): $170 million in 2017.
  29. Braskem S.A. (Brazil): $159.8 million in 2016.
  30. Weatherford International Limited (Switzerland): $152.6 million in 2013.
  31. Alcatel-Lucent S.A. (France): $137 million in 2010.
  32. Avon Products Inc. (United States): $135 million in 2014.
  33. Hewlett-Packard Company (United States): $108 million in 2014.
  34. Magyar Telekom Plc / Deutsche Telekom AG (Hungary /Germany): $95 million in 2011.
  35. Marubeni Corporation (Japan): $88 million in 2014.
  36. Panalpina World Transport (Holding) Ltd. (Switzerland): $81 million in 2010.
  37. Credit Suisse Group AG (Switzerland): $76.7 million in 2018.
  38. General Cable Corporation (United States): $75.75 million in 2016.
  39. Samsung Heavy Industries Company Limited (South Korea): $75 million in 2019.
  40. Johnson & Johnson (United States): $70 million in 2011.

– – –

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.

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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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