ABB In, Titan Out

ABB joins the list of top ten FCPA settlements of all time, coming in at number seven. And after a run of five years in the top ten, Titan Corporation drops to number eleven. That means half the top ten cases are now from 2010, and six involve non-U.S. companies.

They are:

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. ABB Ltd: $58.3 million in 2010.

8. Baker Hughes: $44.1 million in 2007.

9. Willbros: $32.3 million in 2008.

10. Chevron: $30 million in 2007.

Editor's note: This post was updated here.

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Who are candidates to join the top ten?

We'd include:

Alcatel-Lucent, which said six months ago it will pay $137.4 million in a settlement agreed in principle with the DOJ and SEC.

Panalpina has reserved about $110 million for an expected FCPA settlement with the DOJ and SEC, and a separate antitrust resolution. In April it said the settlements should happen "in the near future."

Pride International, Inc. said in February it has set aside $56.2 million for an expected settlement with the DOJ and SEC.

Comments

[Lindsay, i-Sight Case Management Software]

It’s amazing to see that half of this list is comprised of cases from 2010- and the year isn’t even over yet. Another thing that’s interesting is that the settlement dollar values of the 5 cases from 2010 are huge compared to previous cases- with Siemens as an exception. Hopefully other companies will look at lists such as this and think again before taking action that violates the FCPA. Although, based on the results of the recent Kroll study, it looks like companies will also need to brush up on understanding whether or not the FCPA applies to them.