In 2013, twelve companies paid $731.1 million to resolve FCPA cases (that includes IBM's $10 million settlement from 2011 that received final court approval in 2013). Two of the twelve corporate actions -- Total SA and Weatherford -- landed in the top ten FCPA cases of all time.
Entries in 2010 Enforcement Index (18)
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Here's what happened during the second quarter of 2012.
Here's our index of all FCPA enforcement during the past three months . . . . .
The CEOs, CFOs, COOs and Chief Compliance Officers we meet with are well aware of the FCPA and are working to put in place compliance programs to keep their companies on the right side of the law, but they are not terribly concerned about their own personal exposures.
Yesterday we posted our 2011 FCPA enforcement index. Today we look at corporate enforcement for all the years from 2006.
Fifteen companies settled FCPA enforcement actions in 20011 by paying a total of $508.6 million.
Some picks for the year's hottest FCPA headlines are these:
Since the start of 2008, 58 companies (by our count) have settled FCPA-related enforcement actions with the DOJ or SEC or both.
During the calendar quarter just ended, there were two corporate enforcement actions and two individual convictions.. . .
A few years ago, after a dozen or so enterprising law students asked me what FCPA-related topics were ripe for research, I answered with a post on the FCPA Blog.