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Harry Cassin
Publisher and Editor

Andy Spalding
Senior Editor

Jessica Tillipman
Senior Editor

Bill Steinman
Senior Editor

Richard L. Cassin
Editor at Large

Elizabeth K. Spahn
Editor Emeritus

Cody Worthington
Contributing Editor

Julie DiMauro
Contributing Editor

Thomas Fox
Contributing Editor

Marc Alain Bohn
Contributing Editor

Bill Waite
Contributing Editor

Shruti J. Shah
Contributing Editor

Russell A. Stamets
Contributing Editor

Richard Bistrong
Contributing Editor

Eric Carlson
Contributing Editor

Here’s the YTD 2020 Enforcement Index: Another record year for the FCPA?

So far this year, seven companies have paid a total of $2.6 billion in FCPA settlements, already making it the third largest year for financial penalties.

In January, Airbus paid $2.09 billion to resolve FCPA offenses, the largest FCPA penalty to date, and nearly double 2019’s biggest FCPA case — Ericsson’s $1.06 billion settlement.

In February, Cardinal Health paid the SEC $8.8 million to settle China FCPA offenses, the smallest settlement so far this year.

Enforcement in 2020 has been broad, involving companies headquartered in four different countries from six different industries.

Seven companies have received declinations from the SEC, DOJ, or both, including Uber Technologies. In a January SEC filing, Uber said it received notice that the DOJ closed its investigation into possible FCPA violations in Indonesia, Malaysia, China, and India, among other countries, and “will not be pursuing enforcement action.”

Five companies — in five different industries — have disclosed new active FCPA-related investigations, according to FCPA Tracker.

If there’s another top ten settlement, 2020 will have the largest financial penalties ever imposed in a year for FCPA offenses. In 2019, a record enforcement year, fourteen companies paid combined penalties of $2.9 billion.

So far this year, five individuals have been sentenced for FCPA offenses and six others have been indicted.

Among those indicted were two women. They allegedly ran adoption scams involving Ugandan and Polish children. They’re charged with bribing Ugandan officials and defrauding adoptive parents, U.S. authorities, and a Polish regulatory authority.

In February, former Alstom exec Lawrence Hoskins was acquitted by a judge of all seven FCPA-related counts he faced. In March, he was sentenced to 15 months in prison for conspiracy and money laundering charges.

Two individuals have pleaded guilty to FCPA offenses. Two others were granted new trials following their convictions because of ineffective counsel at their jury trials.

The YTD 2020 FCPA enforcement report and prior annual enforcement reports are available to members of FCPA Blog+ here.

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