Another year, another round of high-profile FCPA cases. Continuing our tradition, we present this year’s definitive list of the top Foreign Corrupt Practices Act (FCPA) cases. Let’s delve into the numbers and stories that shaped 2024.
This year has been remarkably active in fines, marking a significant increase over 2023. While 2023 saw a combined total of $902.8 million in FCPA fines, 2024 surged ahead with a staggering $2.25 billion—an increase of approximately 150%. The table below details the year’s major cases, shedding light on the companies, industries, and violations involved.
Breaking Down the Biggest FCPA Cases of 2024
2024 was a year of FCPA enforcement, where high-profile cases were charged with heavy fines.
| Company | Total fine, mUSD | DOJ | SEC | Company specialisation | What fraud | |
| 1 | Raytheon Company | 950,0 | 950 | — | Aerospace and defense | Foreign bribery, defective pricing, and export violations |
| 2 | Gunvor S.A. | 661,7 | 661,7 | — | Energy trading | Bribery and corruption in international oil markets |
| 3 | SAP | 222,2 | 118,8 | 103,4 | Software and technology | Bribery involving contracts in international markets |
| 4 | Trafigura Beheer B.V. | 126,99 | 126,99 | — | Commodities trading | Foreign bribery |
| 5 | McKinsey & Company Africa | 122,8 | 122,8 | — | Consulting services | Bribery of South African government officials |
| 6 | Telefónica Venezolana | 85,26 | 85,26 | — | Telecommunications | Bribery related to Venezuelan operations |
| 7 | Javier Aguilar (Former Oil & Gas Trader) and his co-conspirators | 70,13 | 70,13 | — | Energy trading | Bribery in international trading |
| 8 | 500.com (now BIT Mining Ltd.) | 14,0 | 10 | 4 | Cryptocurrency and gaming | Bribery of Japanese officials |
| Total amount | 2253,08 | 2145,68 | 107,4 |
*Compiled by Ethicontrol based on the DOJ and SEC press releases.
The largest fine was imposed on Raytheon Company, an American aerospace and defense conglomerate, which paid a fine of $950 million for foreign bribery, defective pricing, and export violations— a case newly highlighted in 2024.
Close behind was Gunvor S.A., a Swiss energy trader, fined $661.7 million for its implication in bribery schemes to take control of oil trading in several countries as the misconduct took place from the year 2010 continuing to 2019.
German software leader SAP faced up to $222.2 million in combined fines against by the DOJ and SEC for bribery related to public-sector contracts in various international markets; likewise, Trafigura Beheer B.V., a Dutch commodities trader, paid $126.99 million for bribery schemes done to influence government officials aimed at gaining favorable trading terms throughout 2011–2018.
In Africa, McKinsey & Company Africa was ordered to pay $122.8 million over its role in bribing South African government officials for state-linked contracts, a case that had been linked to highly publicized "State Capture" investigations between 2014 and 2018.
Venezuelan telecom Telefonica Venezolana signed a deal to pay an $85.26 million fine to resolve bribery charges underlying regulatory approvals at home over 2015–2020.
Among individual cases, former energy trader Javier Aguilar and his associates were ordered to pay $70.13 million for conspiring to pay bribes through third-party agents in multiple countries to gain trading advantages.
Finally, there is cryptocurrency and gaming firm BIT Mining Ltd, formerly 500.com, which paid $14 million in fines for bribing Japanese officials to gain regulatory advantages back in 2017 — a case that had previously cropped up in investigations.
In all, the FCPA fines racked up to $2.25 billion for 2024, astoundingly larger than that seen in 2023 with a total of $902.8 million.
Individual cases: without fines, but still facing severe penalties
This year has seen an increasing number of prison sentences as a result of FCPA cases, with individuals across a variety of industries held accountable for their corrupt activities. That trend reflects an increasing commitment to fighting international bribery and corruption.
Former Mozambique Finance Minister Manuel Chang took part in a $2 billion fraud and money-laundering scheme that had siphoned the money to enrich himself and others. The case, when it was brought starting in 2015, marked a significant moment in efforts to stem government corruption in Mozambique. He faces a maximum penalty of 20 years in prison.
Again Javier Aguilar, a former oil and gas trader, was sentenced to six years in prison for conspiring to bribe government officials to secure energy contracts overseas. His prosecution, which was the result of a multi-year investigation into corruption, is coming to an end. He faces a maximum penalty of five years in prison on each of the FCPA counts and 20 years in prison on the money laundering count.
Meanwhile, a Venezuelan court will be sentenced (If convicted) Raul Gorrin Belisario, the head of a major news network, to 20 years in prison for his role in a $1.2 billion money-laundering scheme that included paying off government officials. That highly publicized case brought attention to how deep corruption runs through the system in Venezuela.
Asante Kweku Berko, the former Ghanaian banker, will face (If convicted) 20 years in prison over bribery to clinch energy contracts. His case again pointed out the role financial intermediaries play in facilitating corruption, which has been under investigation since the late 2010s.
Carlos Ramon Polit Faggioni was the former comptroller of Ecuador, but decided to receive bribes in exchange for favorable audits and approvals of contracts. The conviction of Polit marked the end of a case investigated for years about his corrupt activities. He faces up to 20 years in prison for each count of money laundering and conspiracy, and up to 10 years for each count of using illegally obtained funds
Abraham Cigarroa Cervantes, a former finance director at Stericycle Inc., is awaiting sentencing for his role in a $10 million bribery scheme. His case involved corrupt practices to secure contracts in Latin America and was part of a broader investigation into the company.
Three executives of a voting machine company and one, a former Chairman of the Commission on Elections in the Philippines, have been indicted for bribery and money laundering. The case underlines the continuous challenge of ensuring electoral integrity within the country. Each of them will face a maximum penalty of 20 years for each count of international laundering of monetary instruments and conspiracy to commit money laundering.
Like father, like son, John Christopher Polit (son of Carlos Ramon Polit Faggioni), former banker, was sentenced to seven years in prison over acts of international bribery. Indeed, his case gave new impulses toward the role of financial institutions for detection and prevention. He is scheduled to be sentenced on Jan. 30, 2025, and faces a maximum penalty of 10 years in prison.
Finally, former oil and gas trader Glenn Oztemel was sentenced to eight years in prison for bribery and money laundering to reap advantages in the energy market. His conviction is the latest in a series of cases targeting systemic corruption in commodities trading. He faces up to five years in prison for each FCPA-related count and up to 20 years for each money laundering-related count.
Additional infographics
Find out where fraudsters' headquarters are located, the areas with the highest incidence of fraud, and the percentage share of each case in the total fines. Have a look at our detailed infographic on the FCPA cases for 2024.
*Total fines issued by DOJ and SEC. Detailed infographic you can find here.
Check past highlights of FCPA cases:
If you want to discover more about previous FCPA cases, please check our FCPA tag to see our reports from previous years.
Resources:
- U.S. Department of Justice
- U.S. Securities and Exchange Comission
- Manuel Chang's photo
- John Christopher Polit's photo
- Carlos Ramon Polit Faggioni's photo
Share post:
