As part of Goldman Sachs’ record-breaking $3.3 billion FCPA resolution, the SEC ordered the company to disgorge $606.3 million. That’s the second biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading
Last week’s $1.06 billion blockbuster resolution by Sweden’s Ericsson included disgorgement to the SEC of $540 million. By our count that’s the second biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading
Swedish telecom Ericsson agreed Friday to pay the DOJ and SEC over $1 billion in one of the biggest Foreign Corrupt Practices Act enforcement actions ever.… Continue Reading
Last month’s $231 million FCPA resolution by German dialysis giant Fresenius Medical Care included disgorgement to the SEC of $147 million. By our count, that’s the tenth biggest disgorgement ever ordered in an FCPA enforcement action.… Continue Reading
Petrobras’s $1.78 billion FCPA resolution last week included disgorgement of $933.5 million, the biggest ever ordered in an FCPA enforcement action.
The SEC allowed Petrobras to credit against the disgorgement the money it had already paid into a settlement fund for U.S.… Continue Reading
Telia Company AB’s $965.6 million settlement Thursday included disgorgement to the SEC of $457 million, the biggest disgorgement ever ordered in an FCPA enforcement action.
Telia won’t actually pay the SEC $457 million in disgorgement, however.… Continue Reading
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Richard L.… Continue Reading
Last week’s $264 million enforcement action against JPMorgan Chase included disgorgement to the SEC of $130.5 million — the seventh biggest FCPA disgorgement of all time.
The SEC said $105.5 million was disgorgement and $25 million was pre-judgment interest.… Continue Reading
Two recent enforcement actions included disgorgements to the SEC that are among the ten biggest FCPA disgorgments of all time.
As part of its $412 million resolution with the DOJ and SEC in late September, hedge fund manger Och-Ziff Capital Management Group (and its affiliate OZ Africa Management GP LLC) agreed to disgorge about $199 million to the SEC.… Continue Reading
VimpelCom’s $397.6 million FCPA settlement last week included a disgorgement to the SEC that ranks third on our list of the biggest FCPA disgorgements of all time.
The company agreed to pay the SEC $167.5 million in disgorgement and pre-judgment interest.… Continue Reading