TOP 10 FCPA Enforcement Actions, Disgraced Goldman Sachs Tops the List

Posted on 01/13/2021

Goldman Sachs has been a leader in investment banking league tables, but has also been the largest bank on Wall Street facing a major FCPA violation. The Foreign Corrupt Practices Act of 1977 is a United States federal law that prohibits U.S. citizens and entities from bribing foreign government officials to benefit their business interests. The FCPA is jointly enforced by the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC), which apply criminal and civil penalties, respectively.

Many sovereign wealth funds, governments, and public funds continue to do business with these entities.

TOP 10 FCPA Enforcement Actions

Rank Company Resolution Amount in USD DOJ Portion SEC Portion Date Notes
1 Goldman Sachs Group Inc. 1,663,088,000 1,263,088,000 400,000,000 10/22/2020 Other enforcement authorities in the U.K., Singapore, and Hong Kong fined Goldman Sachs. SEC required Goldman Sachs to pay a US$ 400 million civil penalty and disgorgement of US$ 606.3 million. Disgorgement amount was paid to the Malaysian government and 1MDB.
2 Telefonaktiebolaget LM Ericsson 1,060,570,432 520,650,432 539,920,000 12/6/2019  
3 Mobile TeleSystems PJSC 850,000,000 750,000,000 100,000,000 3/6/2019  
4 Siemens AG 800,000,000 450,000,000 350,000,000 12/15/2008 FCPA resolutions were coordinated with a €395 million anti-corruption settlement with the Munich Public Prosecutor.
5 Alstom S.A. 772,290,000 772,290,000   12/22/2014  
6 KBR (Halliburton) 579,000,000 402,000,000 177,000,000 2/11/2009 KBR, Inc. is an American engineering, procurement, and construction company, formerly a subsidiary of Halliburton.
7 Teva Pharmaceutical Industries Ltd. 519,000,000 283,000,000 236,000,000 12/22/2016  
8 Telia Company AB 483,103,972 274,603,972 208,500,000 9/21/2017 In total, U.S., Netherlands, and Sweden financial penalties is US$ 965.6 million.
9 Och-Ziff Capital Management Group 412,000,000 213,000,000 199,000,000 9/29/2016 Rebranded to Sculptor Capital Management.
10 BAE Systems 400,000,000 400,000,000   2/14/2010

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