During the third calendar quarter, there were three corporate FCPA enforcement actions with penalties and disgorgement totaling about $182.7 million.
For comparison, during the third calendar quarter in 2019, there were seven corporate FCPA enforcement actions with penalties and disgorgement totaling about $78.5 million. During Q3 2018, there were also seven corporate FCPA enforcement actions, with total penalties and disgorgement of about $1.97 billion, including $1.78 billion for Petrobras.
This quarter’s largest financial penalty was Herbalife Nutrition, which paid the DOJ and SEC $123 million in August to resolve FCPA violations in China.
Two individuals were sentenced during the third quarter, and three were indicted.
Four individuals entered guilty pleas in Q3.
There were three corporate declinations, including KBR’s Unaoil-related investigation and GSK’s China investigation.
The complete YTD 2020 FCPA Enforcement Report with synopses and links to relevant content for both corporations and individuals is exclusive to FCPA Blog+ members.