In 2015, 11 companies paid about $133 million to resolve FCPA cases. In the year's biggest enforcement action (which wasn't big by historical standards), BHP Billiton paid $25 million to the SEC to settle Olympics-related FCPA offenses.
Entries in 2012 Enforcement Index (7)
From April through June, there were two corporate FCPA enforcement actions. There were also two individual guilty pleas, with one -- by Joseph Sigelman in the midst of his FCPA trial -- resulting in probation only and no jail time.
In 2013, twelve companies paid $731.1 million to resolve FCPA cases (that includes IBM's $10 million settlement from 2011 that received final court approval in 2013). Two of the twelve corporate actions -- Total SA and Weatherford -- landed in the top ten FCPA cases of all time.
DOJ and SEC enforcement of the FCPA slowed a bit during the summer months. But after a blockbuster Q2, the third quarter still saw four guilty pleas, one more than the prior quarter, and three declinations, up from two in the previous three months.
It was a quiet start to the year, with just one stealth enforcement action by the SEC that didn't mentioned the FCPA by name, and none by the DOJ.
Twelve companies settled FCPA enforcement actions in 2012 by paying a total of $259.4 million.