Click on the Archive tab in the top menu of the FCPA Blog to find Our Lists. Included there are FCPA enforcement actions, corporate investigations, the country count for investigations, our current top ten lists, Dean Tillipman’s resources, and more.… Continue Reading
Hewlett-Packard’s $108 million settlement this week didn’t quite make our list of the top ten FCPA cases of all time. But with a disgorgement to the SEC of $26.4 million, H-P landed eleventh on the list of the biggest FCPA disgorgements.… Continue Reading
As part of its $354 million settlement this week, Alcoa agreed to pay the third biggest disgorgement in FCPA history — $161 million.
What is disgorgement? It’s a remedy, according to our contributing editor Marc Alain Bohn, authorized by the Securities Exchange Act of 1934 that’s ‘used to deprive wrong-doers of their ill-gotten gains and deter violations of federal securities law.’… Continue Reading
In the fourth biggest FCPA case ever, French oil giant Total S.A. agreed Wednesday to pay $398 million in penalties and disgorgement for bribing an Iran official to gain access to oil and gas fields.… Continue Reading
As part of its recent settlement with the SEC, Ralph Lauren Corporation agreed to disgorge $593,000 that was “obtained or retained as a result of the violations discovered during the investigation,” along with $141,846 in pre-judgment interest. … Continue Reading
On his great Conflict of Interest Blog, Jeff Kaplan posted the ten biggest U.S. corporate criminal fines of all time.
They add up to more than $6.75 billion.
What’s striking, Jeff says, ‘is that fully half of the ten largest federal corporate criminal fines in history were imposed or agreed to in 2012.’… Continue Reading
The Securities and Exchange Commission said Monday it has resolved an FCPA enforcement action against Germany-based insurance and asset management company Allianz SE.
The company paid the SEC a total of $12.4 million to settle an out-of-court administrative proceeding.… Continue Reading
The DOJ agreed last week to end Pride International’s deferred prosecution agreement a year early to reward the company for its enhanced compliance efforts.