Skip to content


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

I tried to write a post about FCPA enforcement, and this happened

I collect tidbits about FCPA enforcement. During good weeks, the tidbits come together for a post. Other times, they stubbornly remain random factoids. That’s what happened this week. No unified field theory of FCPA enforcement. Just random factoids. For example . . . . . .

Of the 256 corporate FCPA enforcement actions through today, 168 have involved companies headquartered in the United States. That’s 65.6 percent.

One hundred seventy-seven of the 256 cases involved public companies, and 78 involved privately-held companies.

UK companies have been defendants in 15 FCPA enforcement actions. And eight companies came from Switzerland.

Just one company headquartered in Russia has been an FCPA defendant. Mobile TeleSystems (MTS) paid $850 million in 2019 to resolve FCPA offenses. It’s still on our top ten list.

The most recent year when FCPA penalties levied against corporations were $0 was 2003.

Forty-five of the 256 corporate enforcement actions have involved oil and gas producers or energy services companies. Ten cases involved companies from the aerospace industry.

What was the first year when FCPA penalties and disgorgement exceeded $1 billion? It was 2010 at $1.8 billion. The next billion-dollar year was 2014, at about $1.5 billion.

The “smallest” case on our FCPA top ten list is Société Générale S.A. of France with its $585 million resolution in 2018.

So far in 2021, the average corporate FCPA resolution is valued at $70.5 million. In 2020, the average settlement was nearly $535 million. In 2019, it was $207 million, in 2018 about $170 million, and in 2017 $152 million.

Currently, the only Singapore-based company with an ongoing publicly disclosed FCPA-related investigation is Grab Holdings Limited. Two Singapore-based companies have resolved FCPA offenses: Keppel Offshore & Marine Ltd. paid $422 million in 2017, and United Industrial Corporation paid about $337,000 in 2009.

The #1 company on our top ten list is the only U.S.-based company on the list. Goldman Sachs’ 2020 FCPA resolution included total financial sanctions of $3.3 billion. (The DOJ imposed a $2.3 billion criminal penalty; the SEC imposed a civil penalty of $400 million and disgorgement of $606 million.)

How many China-based companies (parent companies, not subsidiaries of non-China companies) have been defendants in FCPA enforcement actions? Just one. Keyuan Petrochemicals Inc. paid $1 million in 2013 to resolve FCPA offenses.


Well, those are this week’s random factoids. Too bad they didn’t come together to make a post. Fortunately, there’s always next week.

Share this post


Comments are closed for this article!