On his FCPA Blog, Richard Cassin recently compiled an interesting chart of the Top 10 FCPA Settlements of All-Time. The list provides some good insights into enforcement trends in the FCPA area:
The top 8 settlements have all occurred since 2008. The oldest case on the list is from 2005.
Total penalties from the top 10 add up to $2.8 billion, with almost 50% of that coming from the top two settlements (Siemens and KBR/Halliburton).
Five of the top 6 involve non-U.S. companies.
The Top 10 settlements as compiled by the FCPA Blog are as follows:
1. Siemens: $800 million in 2008.
2. KBR / Halliburton: $579 million in 2009.
3. BAE: $400 million in 2010.
4. Snamprogetti Netherlands B.V. / ENI S.p.A: $365 million in 2010.
5. Technip S.A.: $338 million in 2010.
6. Daimler AG: $185 million in 2010.
7. Baker Hughes: $44.1 million in 2007.
8. Willbros: $32.3 million in 2008.
9. Chevron: $30 million in 2007.
10. Titan Corporation: $28.5 million in 2005.
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