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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

FCPA enforcement report for Q3 2020

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.

According to FCPA Tracker, five companies disclosed new FCPA-related investigations during the third quarter, including consumer health giant Johnson & Johnson.

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.

Click here to view the full report

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