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Top 10 FCPA enforcement cases of 2017

Last year, the top 10 companies were charged over $2.0 billion to resolve FCPA cases. This amount is much smaller, compared to $7.2 billion in 2016. As predicted, 2017 was not as aggressive as previous years, besides, all major cases were started in prior years. Therefore, we should not expect many cases in 2018.

 

Top 10 FCPA enforcement cases of 2017

 

  Company Total fine, mUSD DOJ SEC Other countries
1 Telia Company AB 966,0 275,0 417,0 274,0
2 SBM Offshore N.V. 478,0 238,0   240,0
3 Keppel Offshore & Marine Ltd. 422,6 105,6   317,0
4 Zimmer Biomet Holdings Inc. 30,4 17,4 13,0  
5 Sociedad Química y Minera de Chile (SQM) 30,0 15,0 15,0  
6 Halliburton Company 29,2   29,2  
7 Las Vegas Sands Corp. 16,0 7,0 9,0  
8 Mondelēz International, Inc. 13,0   13,0  
9 Alere Inc. 13,0   13,0  
10 Orthofix International N.V. 6,0   6,0

 

Top 10 FCPA enforcement cases of 2017

More information you can find here.

 

Despite corporate fines being quite modest, the individual charges were very convincing. According to FCPA Blog: 

  • 4 individuals settled civil FCPA charges brought by the SEC; 
  • 8 were sentenced during the year,
  • 11 pleaded guilty, and one was convicted at trial.
  • 7 individuals were indicted.
  • There were 17 reported declinations in 2017, including two declinations with disgorgement under the Pilot Program.

 

List of sources: