In fiscal year 2018, 16 companies paid a record $2.89 billion to resolve Foreign Corrupt Practices Act (FCPA) cases brought by the U.S. Department of Justice and the Securities and Exchange Commission.
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Last year 16 companies paid a record $2.89 billion to resolve FCPA cases. That includes amounts assessed in resolutions with the DOJ or SEC or both, and through DOJ declinations with disgorgement.
“There were three enforcement actions in the mega-case category—Petrobras ($1.78 billion), SocGen ($585 million), and Panasonic ($280 million).
“(Petrobras and SocGen followed the new structure for global resolutions, with the DOJ and SEC assessing total penalties but allowing the companies to pay some of the penalties to enforcement agencies and regulators in other countries.)
- In 2017, 11 companies paid just over $1.92 billion to resolve FCPA cases.
- In 2016, 27 companies paid $2.48 billion to resolve FCPA cases.
- In 2015, 11 companies paid $133 million.
- In 2014, 10 companies paid $1.56 billion.
- In 2013, 12 companies paid $731.1 million.
- In 2012, 12 companies paid $259.4 million.
- In 2011, 15 companies paid $508.6 million.
- In 2010, 23 companies paid $1.8 billion.
- In 2009, 11 companies paid $644 million, and
- In 2008, 11 companies paid $890 million.
“There were 15 reported declinations in 2018, and separately four so-called declinations with disgorgement under the DOJ’s FCPA Corporate Enforcement Policy (formerly the Pilot Program).
“Four individuals settled civil FCPA charges brought by the SEC.
“During 2018, six individuals pleaded guilty to FCPA-related criminal charges, six others were sentenced, and two others were convicted at trial. Nine additional individuals were indicted for FCPA crimes.”