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Wall Street bank earns top spot on FCPA Blog top ten list

Goldman Sachs Group Inc. shattered our top ten list with a $3.3 billion FCPA settlement with the U.S. Department of Justice and Securities and Exchange Commission, sending it straight to number one.

In last week’s settlement, the DOJ imposed a $2.3 billion criminal penalty, and the SEC imposed a civil penalty of $400 million and disgorgement of $606.3 million.

The DOJ announced the Goldman Sachs settlement at a value of $2.9 billion. The FCPA Blog found no apparent basis for that value. A detailed methodology of how we calculate FCPA settlement amounts is here.

The DOJ said Goldman Sachs’ violations involved $1.6 billion in bribes. The SEC said beginning in 2012, “former senior employees of Goldman Sachs used a third-party intermediary to bribe high-ranking government officials in Malaysia and the Emirate of Abu Dhabi.”

Goldman Sachs replaces KBR as the only American company on the FCPA Blog’s top ten list. Goldman is the first American company to be in the top spot since the FCPA Blog started the top ten list. In 2010, KBR was number two, behind Siemens, and stayed on the list until last week.

Five FCPA settlements have now reached a billion dollars or more, and it takes at least $585 million to even appear in the current top ten.

Total FCPA penalties — since the Act’s inception in 1977 —  are now over $20 billion.

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Here are the ten biggest FCPA cases of all time based on penalties and disgorgement assessed in the U.S. enforcement documents:

  1. Goldman Sachs Group Inc. (United States): $3.3 billion in 2020
  2. Airbus SE (Netherlands/France): $2.09 billion in 2020.
  3. Petróleo Brasileiro S.A. – Petrobras (Brazil): $1.78 billion in 2018.
  4. Telefonaktiebolaget LM Ericsson (Sweden): $1.06 billion in 2019.
  5. Telia Company AB (Sweden): $1.01 billion in 2017.
  6. MTS (Russia): $850 million in 2019.
  7. Siemens (Germany): $800 million in 2008.
  8. VimpelCom (Netherlands): $795 million in 2016.
  9. Alstom (France): $772 million in 2014.
  10. Société Générale S.A. (France): $585 million in 2018.

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  1. Interesting list but it gives only a partial picture. If we take what Goldman Sachs has paid to Malaysia last year and to others like Hong Kong we are beyond 5 billions. In fact it would be nice to have a consolidated list in which all the penalties paid worldwide appear. It would also be interesting to evaluate the 2008 settlement of Siemens and put it in 2020 USD terms (noting that again this does not capture the full picture as Siemens paid a fine also in Germany and in other countries).

  2. Where will the money go: DoJ or SEC or US Treasury ?
    not to Malaysia ?
    paul arlman

  3. An interesting note on the semi political front- in 2016 we had a lot of discussions on what the Trump administration would mean to FCPA enforcement – as we come to a close of the term – the top 6 on the list and 7 out of 10 are settlements that were finalized during the Trump administration

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