Richard L. Cassin Publisher and Editor

Andy Spalding Senior Editor

Jessica Tillipman Senior Editor

Elizabeth K. Spahn Editor Emeritus

Cody Worthington Contributing Editor

Julie DiMauro Contributing Editor

Thomas Fox Contributing Editor

Marc Alain Bohn Contributing Editor

Bill Waite Contributing Editor

Shruti J. Shah Contributing Editor

Russell A. Stamets Contributing Editor

Richard Bistrong Contributing Editor 

Eric Carlson Contributing Editor

Bill Steinman Contributing Editor

Aarti Maharaj Contributing Editor

FCPA Blog Daily News

« Less Secrecy, Please. We're Canadian | Main | Watts Water And Former Employee Settle With SEC »

Sixty-Four Million Reasons To Comply

Since the start of 2008, 58 companies (by our count) have settled FCPA-related enforcement actions with the DOJ or SEC or both. Together they paid $3.74 billion in penalties, disgorgement, and interest -- an average of $64.5 million per enforcement action.

The yearly numbers break down this way:

In 2011 year-to-date, 13 companies have paid $405.6 million, for an average settlement of $31.2 million (including $28 million paid in an FCPA settlement that also included a price-fixing count).

In 2010, 23 companies paid $1.8 billion for an average settlement of $78 million.

In 2009, 11 companies paid $644 million, averaging $58.5 million per corporate FCPA enforcement action.

In 2008, 11 companies paid $890 million for an average of $80 million. Excluding Siemens' $800 million resolution, 10 companies paid $90 million for an average of $9 million (Siemens is included in the $64.5 million overall average for the period in question).

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Managing compliance risks. More than 100 companies -- many of them global leaders -- took part in the Anti-Corruption Compliance Program Benchmarking Survey. The findings (available here) should help those seeking to assess or improve their compliance programs.

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