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« 'Inside he was an iron man' | Main | China Corruption Blotter (January 4, 2013) »
Friday
Jan042013

Kaplan's Top Ten Corporate Criminal Fines

On his great Conflict of Interest Blog, Jeff Kaplan posted the ten biggest U.S. corporate criminal fines of all time.

They add up to more than $6.75 billion.

What's striking, Jeff says, 'is that fully half of the ten largest federal corporate criminal fines in history were imposed or agreed to in 2012.'

But as Jeff said in his post, the 'list is based only on federal corporate criminal fines. Many of the cases here also involved federal or state criminal forfeitures, regulatory or civil penalties, and/or criminal (as well as other) fines or judgments imposed in other countries  – none of which were included in developing this list.'

Two FCPA cases are named -- Siemens and KBR / Halliburton. They account for $852 million. (Jeff's numbers include only DOJ criminal fines and not SEC civil penalties and disgorgements).

On his list of the top corporate criminal fines of all time are:

1.  BP – $1.256 billion (environmental and related offenses) (2012)

2.  Pfizer – $1.2 billion (marketing offenses) (2009)

3.  GlaxoSmithKline – $956 million (marketing offenses) (2012)

4.  Eli Lilly – $515 million (marketing offenses) (2009)

5.  AU Optronics – $500 million (antitrust) (2012)

6.  Abbott Laboratories – $500 million (marketing offenses) (2012)

7.  Hoffman-LaRoche – $500 million (antitrust) (1999)

8.  Yakazi – $470 million (antitrust) (2012)

9.  Siemens – $450 million (FCPA) (2009)

10. Halliburton/KBR – $402 million (FCPA) (2008)

*     *     *

Jeff Kaplan's full post is here.

Our top ten FCPA enforcement actions are here.

And our top ten FCPA disgorgements are here.

References (2)

References allow you to track sources for this article, as well as articles that were written in response to this article.
  • Response
    Kaplan's Top Ten Corporate Criminal Fines - The FCPA Blog - The FCPA Blog
  • Response
    Chandicharan charges down the wet steps leading to the river and collects handfuls of Longchamp taschen gooey, malleable mud. He does this repeatedly till he has stocked enough for the day, well ahead of Longchamp taschen the hour when the river bank will beryllium submerged in the high tide. As he ...

Reader Comments (3)

This appears to be missing the LIBOR actions as well as ING (not DOJ but OFAC) as well as HSBC. The list is good, but a little myopic?
January 3, 2013 | Unregistered CommenterWhere are the banks
Jeff's list is strictly limited to DOJ criminal fines. As he said in his original post: 'I should also emphasize that this list is based only on federal corporate criminal fines. Many of the cases here also involved federal or state criminal forfeitures, regulatory or civil penalties, and/or criminal (as well as other) fines or judgments imposed in other countries – none of which were included in developing this list.'
January 4, 2013 | Registered CommenterRichard L. Cassin
Can anyone point me to any case where a mitigating factor for effective procedures has been calculated to reduce a sentence or DPA sanction?
January 4, 2013 | Unregistered CommenterMike Comer

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