SEC Enforcement Actions: FCPA Cases

June 7, 2021

Enforcement of the Foreign Corrupt Practices Act (FCPA) continues to be a high priority area for the SEC. In 2010, the SEC's Enforcement Division created a specialized unit to further enhance its enforcement of the FCPA, which prohibits companies issuing stock in the U.S. from bribing foreign officials for government contracts and other business.

The following is a list of the SEC's FCPA enforcement actions listed by calendar year:

2024

  • RTX Corporation agreed to pay over $124 million in disgorgement, prejudgment interest and a civil penalty (to be offset by $22.5 million to be paid to DOJ) to resolve FCPA anti-bribery, recordkeeping, and internal accounting controls charges arising out of conduct in Qatar. This settlement concerns multiple schemes by Raytheon Company, now RTX Corporation (“Raytheon”), to obtain defense contracts in Qatar from 2015 through 2022, including Raytheon paying bribes to Qatari military and other foreign officials through sham subcontracts with a supplier. (10/16/2024) SEC Order
  • Moog Inc., a New York-based global manufacturer of motion controls systems for aerospace, defense, industrial, and medical markets, agreed to pay over $1.5 million in disgorgement, prejudgment interest and a civil penalty to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA arising out of bribes paid by its wholly owned Indian subsidiary, Moog Motion Controls Private Limited. The SEC alleges that from 2020 through 2022, Moog Motion Controls employees bribed Indian government officials to win multiple government contracts and also offered cash bribes to Indian officials in an attempt to cause public tenders in India to favor Moog’s products and exclude competitors. The order finds that the bribes were funneled through third-party agents and distributors. (10/11/2024) SEC Order
  • Deere & Company, which does business as John Deere, agreed to pay nearly $10 million in disgorgement, prejudgment interest and a civil penalty to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA arising out of bribes paid by its wholly owned subsidiary, Wirtgen Thailand. The SEC alleges that from at least late 2017 through 2020, Wirtgen Thailand employees bribed Thai government officials with the Royal Thai Air Force, the Department of Highways, and the Department of Rural Roads to win multiple government contracts and also bribed employees of a private company to win sales to that company. The order finds that the bribes included cash payments, massage parlor visits, and international travel for the government officials and private company employees. (9/10/24) SEC Order
  • SAP SE agreed to a settled C&D order for violating the anti-bribery, recordkeeping, and internal accounting controls provisions of the FCPA and to pay $98 million in disgorgement and PJI (to be offset by up to $59 million to be paid to South African authorities). SAP, through its wholly-owned subsidiaries, employed third-party intermediaries and consultants in various schemes to pay bribes to government officials in order to obtain business in South Africa, Malawi, Kenya, Tanzania, Ghana, Indonesia, and Azerbaijan. (1/10/24) SEC Order

2023

  • Albemarle Corporation agreed to pay approximately $103.6 million in disgorgement and prejudgment interest to resolve FCPA anti-bribery, recordkeeping, and internal accounting controls charges arising out of certain conduct in Vietnam, India, Indonesia, China, and the United Arab Emirates. (9/29/23) SEC Order
  • Clear Channel Outdoor Holdings, Inc. agreed to pay approximately $26.1 million in disgorgement and prejudgment interest arising out of bribes paid by its agent, a former majority-owned affiliate in China, in violation of the FCPA’s anti-bribery, recordkeeping, and internal accounting controls provisions.   (9/28/23) SEC Order
  • 3M Company – Minnesota-based 3M agreed to pay more than $6.5 million to resolve charges that it violated the books and records and internal controls provisions of the FCPA.  Employees of a 3M China-based subsidiary arranged for Chinese health care officials to attend overseas conferences, educational events, and health care facility visits ostensibly as part of its marketing and outreach efforts, but that in fact were often a pretext to provide overseas travel, sightseeing and entertainment. (8/25/23) SEC Order
  • Grupo Aval – Colombian conglomerate Grupo Aval Acciones y Valores S.A. (Grupo Aval S.A.) and its bank subsidiary Corporación Financiera Colombiana S.A. (Corficolombiana) agreed to pay $40 million to resolve charges that they violated the books and records and internal accounting controls provisions and, in the case of Corficolombiana, the anti-bribery provisions of the FCPA, in connection with an extension to a highway infrastructure project in Colombia. The SEC alleges that Corficolombiana, through its former president and with a joint venture partner, paid at least $28 million in bribes to secure the extension (08/10/23).
  • Gartner, Inc. – A research and consulting services company agreed to pay over $2.45 million to resolve charges that it violated the anti-bribery, books and records, and internal accounting control provisions of the FCPA in connection with a corrupt arrangement with a South African consulting firm to obtain and retain contracts from the South African Revenue Service. (5/26/2023) SEC Order
  • Koninklijke Philips N.V. – The medical device manufacturer agreed to pay $62 million to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA, in connection with the operations of its subsidiaries in China.  For several years, employees at Philips’ Chinese subsidiaries, distributors or sub-dealers sought to improperly influence government hospital officials, including through the use of price discounts that increased the risk of payments to the government officials, to increase the likelihood that Philips’ products would be selected in public tenders.  They further corrupted public tenders by colluding with other manufacturers’ employees to create false accompanying bids to give the appearance of a legitimate public tender. (05/11/23).
  • Frank’s International N.V. – An oil services company agreed to pay approximately $8 million to resolve charges that it violated the FCPA’s anti-bribery, books and records, and internal accounting controls provisions in connection with payments made by its subsidiaries to an Angolan government official through a purported sales agent.  (4/26/23)
  • Flutter Entertainment plc, as successor-in-interest to The Stars Group, Inc. - The company agreed to pay a $4 million civil penalty to resolve charges that it violated the books and records and internal accounting control provisions of the FCPA in connection with approximately $8.9 million in payments to consultants in Russia in support of the company’s operations and its efforts to have poker legalized in that country. (03/06/23)
  • Rio Tinto plc - The company agreed to pay a $15 million civil penalty to resolve charges that it violated the books and records and internal accounting control provisions of the FCPA in connection with the payment of $10.5 to a consultant to help the company retain mining rights to certain blocks in the Simandou mountain region in Guinea by offering or paying money to benefit a Guinean government official. (03/06/23)

2022

  • Honeywell International Inc. -- The company agreed to pay more than $81 million to settle the SEC’s charges that it violated the anti-bribery, books and records, and international accounting violations of the FCPA arising out of bribery schemes in Brazil and Algeria. In 2010, Honeywell offered at least $4 million in bribes to a high-ranking Brazilian government official in connection with the bidding process at Petrobras, Brazil’s state-owned oil company. In 2011, employees and agents of Honeywell’s Belgian subsidiary paid more than $75,000 in bribes to an Algerian government official to obtain and retain business with the Algerian state-owned entity Sonatrach. The SEC’s Order provides for an offset of up to $38.7 million of payments made to the Brazilian government to settle charges relating to the Brazilian bribery scheme. (12/19/22).
  • ABB -- A Switzerland-based global electrification and automation company was ordered to pay more than $147 million to resolve charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with a bribery scheme in South Africa; specifically, $75 million in a civil monetary penalty, $58 million in disgorgement and over $14.5 million in prejudgment interest. Payment of the penalty and prejudgment interest were deemed satisfied by an earlier payment of ill-gotten gain to the government of South Africa. (12/3/22).
  • Oracle Corporation – The company agreed to pay more than $23 million to settle charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with violations at its subsidiaries in Turkey, the United Arab Emirates, and India. (9/27/22).
  • Gol Intelligent Airlines Inc. – The second largest carrier in Brazil agreed to pay more than $160 million to the SEC, DOJ, and Brazilian authorities to resolve anti-bribery, books and records, internal accounting controls, and other related charges, for its involvement in a bribery scheme that a senior executive orchestrated. The U.S. authorities waived all but $41.5 million due to its inability to pay. (9/15/22)
  • Tenaris -- A Luxembourg-based global manufacturer and supplier of steel pipe products, agreed to pay more than $78 million to resolve charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with a bribery scheme involving its Brazilian subsidiary.  (6/2/22)
  • Stericycle, Inc. – A leading provider of medical waste and other services agreed to pay more than $28 million to settle SEC charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with violations at its subsidiaries in Argentina, Brazil, and Mexico. (4/20/22)
  • KT Corporation -- The largest South Korean Telecommunications company agreed to pay more than $6.3 million to settle charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with improper payments for the benefit of government officials in Korea and Vietnam.  (2/17/2022)

2021

  • Credit Suisse --  The firm agreed to pay nearly $100 million in disgorgement, PJI and penalty to settle charges that it violated the anti-fraud provisions of the federal securities laws and the books and records and internal accounting controls provisions of the FCPA in connection with its role in three financial transactions on behalf of Mozambican state-owned entities. See related action VTB Capital.  (10/19/21)
  • WPP plc – The world’s largest advertising group agreed to pay more than $19 million to settle charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with violations at its subsidiaries in India, Brazil, China, and Peru. (9/24/21)
  • Amec Foster Wheeler Ltd. -- The company agreed to pay $22.7 million to settle SEC charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with a scheme to obtain an oil and gas engineering and design contract from the Brazilian state-owned oil company, Petroleo Brasileiro S.A. (6/25/21)
  • Asante Berko - SEC charged a former executive of a financial services company with orchestrating a bribery scheme to help a client to win a government contract to build and operate an electrical power plant in the Republic of Ghana. See Litigation Release for Final Judgment. (6/23/21)
  • Deutsche Bank AG - The firm agreed to pay more than $43 million in disgorgement and PJI to settle charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with improper payments to intermediaries in China, the UAE, Italy and Saudi Arabia. (1/8/21)

2020

  • Goldman Sachs Group, Inc. - The firm agreed to pay more than more than $1 billion to settle SEC charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with the 1Malaysia Development Berhad (1MDB) bribe scheme. See related action against Tim Leissner (10/22/20).
  • J&F Investimentos, S.A. - Brazilian nationals Joesley Batista and Wesley Batista and their companies J&F Investimentos S.A. and JBS S.A., a global meat and protein producer, have agreed to pay nearly $27 million to resolve charges that they caused Pilgrim’s Pride’s violations of the books and records and internal accounting controls provisions of the FCPA. The Batistas also agreed to each pay a $550,000 civil penalty. The parties also agreed to a three-year self-reporting undertaking. (10/14/20)
  • Herbalife Nutrition, Ltd. - The Los Angeles-based direct selling company agreed to pay more than $67 million to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA arising out of a bribery scheme orchestrated by its China subsidiary. See related action against Jerry Li. (9/28/20)
  • World Acceptance Corp. (“WAC”) - Without admitting or denying the SEC’s findings, WAC settled to anti-bribery, books and records, and internal accounting controls provisions of the FCPA and paid over $20 million to resolve charges arising out of a bribery scheme orchestrated by its former Mexican subsidiary. (8/6/2020)
  • Alexion Pharmaceuticals - Boston-based pharmaceutical company Alexion Pharmaceuticals Inc. agreed to pay more than $21 million to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA. (7/2/20)
  • Novartis AG - Global pharmaceutical and healthcare company and its former Alcon subsidiary agreed to pay over $340 million to resolve SEC and DOJ charges arising out of conduct in multiple jurisdictions. (6/25/20)
  • ENI S.p.A. - Italian multinational oil and gas company agreed to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with an improper payment scheme in Algeria. (4/17/20)
  • Cardinal Health - Ohio-based pharmaceutical company Cardinal Health, Inc. agreed to pay more than $8 million to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with its operations in China. (2/28/20)

2019

  • Tim Leissner - A former executive of Goldman Sachs Group Inc. agreed to a settlement with the SEC that includes a permanent bar from the securities industry for violating the FCPA by engaging in a corruption scheme, by which he obtained millions of dollars by paying unlawful bribes to various government officials to secure lucrative contracts for Goldman Sachs. (12/16/19).
  • Ericsson – The multinational telecommunications company agreed to pay more than $1 billion to the SEC and DOJ to resolve charges that it violated the FCPA by engaging in a large-scale bribery scheme involving the use of sham consultants to secretly funnel money to government officials in multiple countries. (12/6/19)
  • Jerry Li – SEC charged Jerry Li, a Chinese national and former managing director of the Chinese subsidiary of a U.S.-based direct selling company listed on the NYSE, for bribing government officials in China to obtain direct selling licenses made through payments of cash, gifts, travel, meals and entertainment. (11/15/19)
  • Westport and Nancy Gougarty – SEC charged this Canadian issuer and its former CEO Gougarty with bribing a Chinese government official in violation of the FCPA along with related violations of the books and records and internal accounting controls provisions. Westport and Gougarty agreed to pay more than $4.1 million to settle the charges. (9/27/19)
  • Barclays – The UK-based bank agreed to pay $6.3 million to settle violations of the internal accounting controls and recordkeeping provisions in connection with its hiring practices in Asia. (9/27/19)
  • Quad/Graphics, Inc. – the marketing solutions and printing service provider agreed to pay nearly $10,000,000 to resolve charges that it violated the FCPA by engaging in multiple bribery schemes in Peru and China, and creating false records to conceal commercial transactions with a state-controlled Cuban telecommunications company that were subject to U.S. sanctions and export controls laws. (9/26/19)
  • TechnipFMC plc – The global oil and gas services company agreed to pay more than $5 million to resolve violations of the FCPA’s anti-bribery, internal accounting controls and recordkeeping provisions by FMC Technologies prior to its 2017 merger with Technip S.A. for conduct related to Iraq. (9/19/19)
  • Sridhar Thiruvengadam – agreed to settle charges relating to his role in a bribery scheme while serving as chief operating officer of Cognizant, a New Jersey-based technology company. (9/13/19) See related actions against Cognizant (2/15/19) and Coburn and Schwartz. (2/15/19)
  • Juniper Networks – The California-based telecommunications company agreed to pay more than $11.7 million to resolve violations of the FPCA's internal accounting controls and recordkeeping provisions in China and Russia. (8/29/19)
  • Deutsche Bank AG – Deutsche Bank AG agreed to pay more than $16 million to resolve violations of the FCPA's internal accounting controls and recordkeeping provisions in connection with its hiring practices. (8/22/19)
  • Microsoft Corporation – The company agreed to pay more than $24 million to settle SEC charges related to FCPA violations in Hungary, Thailand, Saudi Arabia and Turkey and criminal charges related to Hungary. (7/22/19)
  • Walmart Inc. – SEC charged Walmart with violating the books and records and internal accounting controls provisions of the FCPA by failing to operate a sufficient anti-corruption compliance program for more than a decade as the retailer experienced rapid international growth. Walmart agreed to pay more than $144 million to settle the SEC’s charges and approximately $138 million to resolve parallel criminal charges by the DOJ for a combined total of more than $282 million. (6/20/19)
  • Telefônica Brasil S.A. – SEC charged telecommunications company Telefônica Brasil with violating the accounting provisions of the FCPA when it sponsored the attendance of government officials at the World Cup and Confederations Cup. Telefônica Brasil agreed to pay a $4,125,000 penalty to settle the case. (5/9/19)
  • Fresenius Medical Care AG & Co. – the German based provider of products and services for individuals with chronic kidney failure has agreed to pay $231 million to the SEC and Department of Justice in a global settlement to resolve violations of the FCPA in multiple countries over the course of nearly a decade. (3/29/19)
  • Mobile TeleSystems PJSC – the Russian-based telecommunications provider agreed to pay $850 million in a global settlement to resolve violations of the FCPA to win business in Uzbekistan. (3/6/19)
  • Cognizant – The New Jersey-based technology company agreed to pay $25 million to settle violations of the anti-bribery, internal accounting controls, and recordkeeping provisions. (2/15/19)
  • Gordon Coburn and Steven E. Schwartz – the former Cognizant officials were charged with authorizing $2.5 million in bribe payments to a government official in India. (2/15/19)

2018

  • Polycom – The San Jose-based provider of communications products has agreed to pay more than $16 million to settle charges that its Chinese subsidiary facilitated improper payments to government officials (12/26/18)
  • Centrais Elétricas Brasileiras S.A. – The Brazil-based power generation, transmission, and distribution company agreed to pay a $2.5 million penalty for violating the accounting provisions of the FCPA after former officers at its subsidiary engaged in a bribery scheme involving the construction of a nuclear power plant. (12/26/18)
  • Paul A. Margis and Takeshi “Tyrone” Uonaga – The former senior executives of the U.S. subsidiary of Panasonic Corp. agreed to pay penalties for knowingly violating the books and records and internal accounting controls provisions. NOTE: Panasonic settled charges in April 2018. (12/18/18)
  • Vantage Drilling International – The Houston-based offshore drilling company agreed to pay $5 million to settle charges that its predecessor violated internal accounting controls provisions. (11/19/18)
  • Stryker Corp. – The Michigan-based medical device company agreed to pay a $7.8 million penalty for insufficient internal accounting controls and inaccurate books and records. (9/28/18)
  • Petróleo Brasileiro S.A. – The Brazil-based oil-and-gas company agreed to pay $1.78 billion in a global resolution arising out of a massive bribery and bid-rigging scheme. (9/27/18)
  • Patricio Contesse González – Agreed to pay $125,000 to resolve charges that he violated the FCPA while serving as CEO of Chilean-based chemical and mining company Sociedad Química y Minera de Chile S.A. (9/25/18)
  • United Technologies – The Connecticut-based company agreed to pay nearly $14 million to settle charges that it made illicit payments to facilitate sales of elevators and aircraft engines. (9/12/18)
  • Joohyun Bahn – A New Jersey-based real estate broker agreed to settle charges that he attempted to bribe a foreign official while brokering the sale of a high-rise commercial building on behalf of a foreign private issuer. (9/6/18)
  • Sanofi – Agreed to pay more than $25 million to resolve charges related to corrupt payments to win business in Kazakhstan and the Middle East. (9/4/18)
  • Legg Mason – Agreed to pay more than $34 million to settle charges related to a scheme to bribe Libyan government officials. (8/27/18)
  • Credit Suisse Group AG – Agreed to pay more than $30 million to the SEC and a $47 million criminal penalty to resolve charges that the firm obtained investment banking business in the Asia-Pacific region by corruptly influencing foreign officials in violation of the FCPA. (7/5/18)
  • Beam Suntory Inc.–Agreed to pay more than $8 million to resolve charges that its Indian subsidiary violated the FCPA by using third-party distributors to make illicit payments to increase sales orders, process licensing registrations, and acquire non-public data. (7/2/2018)
  • Panasonic Corp. – The Japan-based company agreed to pay more than $143 million to resolve FCPA charges involving a lucrative consulting position it offered to a government official at a state-owned airline to induce the official to help its U.S. subsidiary in obtaining and retaining business from the airline. (4/30/18)
  • The Dun & Bradstreet Corp. – The company agreed to pay more than $9 million in disgorgement, interest and a civil penalty to resolve FCPA violations stemming from improper payments made by two Chinese subsidiaries. (4/23/18)
  • Kinross Gold – The Canada-based gold mining company agreed to pay a $950,000 penalty to resolve FCPA violations arising from its repeated failure to implement adequate accounting controls of two subsidiaries in Africa. (3/26/18)
  • Elbit Imaging – The Israel-based company agreed to pay a $500,000 penalty to resolve FCPA violations stemming from payments to consultants for purported services related to a real estate development project in Romania. (3/9/18)

2017

  • Telia – The Sweden-based telecommunications provider agreed to pay $965 million in a global settlement to resolve violations of the FCPA to win business in Uzbekistan. (9/21/17)
  • Alere, Inc. – A Massachusetts-based medical manufacturer has agreed to pay more than $13 million to settle charges that it committed accounting fraud through its subsidiaries to meet revenue targets and made improper payments to foreign officials to increase sales in certain countries. (9/28/2017)
  • Halliburton – The company agreed to pay $29.2 million and a former vice president agreed to pay a $75,000 penalty to settle charges related to payments made to a local company in Angola in the course of winning lucrative oilfield services contracts. (7/27/17)
  • Michael L. Cohen and Vanja Baros – The former Och-Ziff executives were charged with being the driving forces behind a far-reaching bribery scheme that paid tens of millions of dollars in bribes to high-level government officials in Africa. (1/26/17)  NOTE: Och-Ziff and other executives settled charges in 2016.
  • Orthofix International – The Texas-based medical device company agreed to pay more than $6 million to settle charges that its subsidiary in Brazil used high discounts and improper payments to induce doctors under government employment to use Orthofix products. (1/18/17)
  • SQM - Chilean-based chemical and mining company Sociedad Quimica y Minera de Chile S.A. agreed to pay more than $30 million to resolve parallel civil and criminal cases finding that it violated the FCPA by making improper payments to Chilean political figures and others. (1/13/17)
  • Biomet - The Warsaw, Ind.-based medical device manufacturer agreed to pay more than $30 million to resolve SEC and Justice Department investigations into the company's anti-bribery violations in Brazil and Mexico. (1/12/17)
  • Cadbury Limited/Mondelez International - The global snacking business agreed to pay a $13 million penalty for FCPA violations occurring after Mondelez (then Kraft Foods Inc.) acquired Cadbury and its subsidiaries, including one in India that proceeded to make illicit payments to obtain government licenses and approvals for a chocolate factory in Baddi. (1/6/17)

2016

  • General Cable Corporation - The Kentucky-based wire and cable manufacturer agreed to pay more than $75 million to resolve SEC and Justice Department cases related to improper payments to win business in Angola, Bangladesh, China, Egypt, Indonesia, and Thailand. (12/29/16)
  • Karl J. Zimmer - The former Vice President of General Cable Corporation agreed to pay $20,000 to resolve charges that he circumvented internal accounting controls and violated the FCPA when he approved certain improper payments. (12/29/2016)
  • Teva Pharmaceutical - The global generic drug manufacturer agreed to pay $519 million to settle parallel civil and criminal charges that it paid bribes to foreign government officials in Russia, Ukraine, and Mexico. (12/22/16)
  • Braskem S.A. - The Brazilian-based petrochemical manufacturer agreed to pay $957 million in a global settlement for concealing millions of dollars in illicit bribes paid to Brazilian government officials to win business. (12/21/16)
  • JPMorgan - The firm agreed to pay $264 million to the SEC, Justice Department, and Federal Reserve to settle charges that it corruptly influenced government officials and won business in the Asia-Pacific region by giving jobs and internships to their relatives and friends. (11/17/16)
  • Embraer - The Brazilian-based aircraft manufacturer agreed to pay $205 million to settle charges that it violated the FCPA to win business in the Dominican Republic, Saudi Arabia, Mozambique, and India. (10/24/16)
  • GlaxoSmithKline – The UK-based pharmaceutical company agreed to pay a $20 million penalty to settle charges that it violated the FCPA when its China-based subsidiaries engaged in pay-to-prescribe schemes to increase sales. (9/30/16)
  • Och-Ziff - The hedge fund and two executives settled charges related to the use of intermediaries, agents, and business partners to pay bribes to high-level government officials in Africa. Och-Ziff agreed to pay $412 million in civil and criminal matters, and CEO Daniel Och agreed to pay $2.2 million to settle charges against him. (9/29/16)
  • Anheuser-Busch InBev - The Belgium-based global brewery agreed to pay $6 million to settle charges that it violated the FCPA by using third-party sales promoters to make improper payments to government officials in India and chilled a whistleblower who reported the misconduct. (9/28/16)
  • Nu Skin Enterprises - The Provo, Utah-based skin care products company agreed to pay more than $765,000 for an improper payment made to a charity related to a high-ranking member of China's Communist Party in order to influence the outcome of a pending provincial regulatory investigation in China. (9/20/16)
  • Jun Ping Zhang - The former chairman/CEO of Harris Corporation's subsidiary in China agreed to pay a $46,000 penalty for violating FCPA by facilitating a bribery scheme that provided illegal gifts to Chinese government officials in order to obtain and retain business for the company. (9/13/16)
  • AstraZeneca - The U.K.-based biopharmaceutical company agreed to pay more than $5 million to settle FCPA violations resulting from improper payments made by subsidiaries in China and Russia to foreign officials. (8/30/16)
  • Key Energy Services - The Houston-based oil field services company agreed to pay $5 million to settle charges that it violated the FCPA as a result of payments made by its Mexican subsidiary to an official responsible for negotiating contracts at Mexico's state-owned oil company. (8/11/16)
  • LAN Airlines - The South American-based airline agreed to pay more than $22 million to settle parallel civil and criminal cases related to improper payments authorized during a dispute between the company and union employees in Argentina. (7/25/16)
  • Johnson Controls - The Wisconsin-based global provider of HVAC systems agreed to pay more than $14 million to settle charges that its Chinese subsidiary used sham vendors to make improper payments to employees of Chinese government-owned shipyards and other officials to win business. (7/11/16)
  • Analogic Corp. and Lars Frost - The Massachusetts-based medical device manufacturer agreed to pay nearly $15 million to settle parallel SEC and DOJ actions after its Danish subsidiary acted as a conduit for distributors to funnel money to third parties in hundreds of highly suspicious transactions. Frost, the subsidiary's CFO at the time, agreed to settle SEC charges and pay a penalty. (6/21/16)
  • Akamai Technologies - SEC announced a non-prosecution agreement (NPA) with the Massachusetts-based internet services provider in which the company will disgorge more than $650,000 in profits connected to bribes paid to Chinese officials by a foreign subsidiary. Akamai promptly self-reported the misconduct and cooperated extensively with the SEC's investigation. (6/7/16)
  • Nortek - SEC announced a non-prosecution agreement (NPA) with the Rhode Island-based residential and commercial building products manufacturer in which the company will disgorge nearly $300,000 in profits connected to bribes paid to Chinese officials by a foreign subsidiary. Nortek promptly self-reported the misconduct and cooperated extensively with the SEC's investigation. (6/7/16)
  • Las Vegas Sands - The casino and resort company agreed to pay $9 million to settle charges that it failed to properly authorize or document millions of dollars in payments to a consultant facilitating business activities in China and Macao. (4/7/16)
  • Novartis AG - The Swiss-based pharmaceutical company agreed to pay $25 million to settle charges that it violated the FCPA when its China-based subsidiaries engaged in pay-to-prescribe schemes to increase sales. (3/23/16)
  • Nordion Inc. and employee - The Canadian-based health science company and a former employee agreed to collectively pay more than $500,000 to settle FCPA charges. Mikhail Gourevitch, an engineer, arranged bribes to Russian officials for drug approvals and received kickbacks in return. Nordion lacked sufficient internal controls to detect and prevent the scheme. (3/3/16)
  • Qualcomm - The San Diego-based company agreed to pay $7.5 million to settle charges that it violated the FCPA when it hired relatives of Chinese officials deciding whether to select company's products. (3/1/16)
  • VimpelCom - The Dutch-based telecommunications provider agreed to a $795 million global settlement to resolve its violations of the FCPA to win business in Uzbekistan. (2/18/16)
  • PTC - The Massachusetts-based tech company and its Chinese subsidiaries agreed to pay more than $28 million to settle FCPA cases involving bribery of Chinese government officials to win business. (2/16/16)
  • SciClone Pharmaceuticals - The California-based pharmaceutical firm agreed to pay $12 million to settle SEC charges that it violated the FCPA when international subsidiaries increased sales by making improper payments to health care professionals employed at state health institutions in China. (2/4/16)
  • Ignacio Cueto Plaza - The airline executive agreed to pay a $75,000 penalty to settle SEC charges that he violated the FCPA when he authorized improper payments to a third-party consultant who he knew could route portions of the money to union officials in the midst of a labor dispute. (2/4/16)
  • SAP SE - The software manufacturer agreed to give up $3.7 million in sales profits to settle SEC charges that it violated the FCPA when its deficient internal controls enabled an executive to pay bribes to procure business in Panama. (2/1/16)

2015

  • Bristol-Myers Squibb - SEC charged the New York-based pharmaceutical company with violating the FCPA when employees of its China-based joint venture made improper payments to obtain sales.  Bristol-Myers Squibb agreed to pay more than $14 million to settle charges. (10/5/15)
  • Hitachi - SEC charged the Tokyo-based conglomerate with violating the FCPA by inaccurately recording improper payments to South Africa's ruling political party in connection with contracts to build power plants. Hitachi agreed to pay $19 million to settle charges. (9/28/15)
  • BNY Mellon - SEC charged the global investment company with violating the FCPA by providing valuable student internships to family members of foreign government officials affiliated with a Middle Eastern sovereign wealth fund. BNY Mellon agreed to pay $14.8 million to settle charges. (8/18/15)
  • Vicente E. Garcia - SEC charged a former SAP SE executive with violating the FCPA by bribing Panamanian government officials through an intermediary to procure software license sales and receiving more than $85,000 in kickbacks. Garcia agreed to settle the case and return the kickbacks plus interest. (8/12/15)
  • Mead Johnson Nutrition – SEC charged the infant formula manufacturer with violating the FCPA when its Chinese subsidiary made improper payments to health care professionals to recommend the company's product to new and expectant mothers. Mead Johnson Nutrition agreed to pay $12 million to settle the case. (7/28/15)
  • BHP Billiton - SEC charged global resources company BHP Billiton with violating the FCPA when it sponsored the attendance of foreign government officials at the Summer Olympics. BHP Billiton agreed to pay a $25 million penalty to settle the case. (5/20/15)
  • FLIR Systems - SEC charged Oregon-based FLIR Systems with violating the FCPA by financing a "world tour" of personal travel for Middle East government officials who played key roles in decisions to purchase FLIR products. FLIR, which earned more than $7 million in profits from such sales, agreed to pay $9.5 million to settle the charges. (4/8/15)
  • Goodyear Tire & Rubber Company - SEC charged Goodyear with violating the FCPA when its subsidiaries paid bribes to land tire sales in Kenya and Angola. The company agreed to pay $16 million to settle the charges. (2/24/15)
  • Walid Hatoum / PBSJ Corporation - SEC charged a former officer at a Tampa, Fla.-based engineering firm with violating the FCPA by offering and authorizing bribes and employment to foreign officials to secure Qatari government contracts. Hatoum agreed to settle the charges, and PBSJ entered into a deferred prosecution agreement and must pay $3.4 million. (1/22/15)

2014

  • Avon Products Inc. - SEC charged the global beauty products company with violating the FCPA by failing to put controls in place to detect and prevent payments and gifts to Chinese government officials from a subsidiary. Avon agreed to pay $135 million to settle the SEC charges and a parallel criminal case. (12/17/14)
  • Bruker Corporation - SEC charged the Billerica, Mass.-based global manufacturer of scientific instruments with violating the FCPA by providing non-business related travel and improper payments to various Chinese government officials in an effort to win business. The company agreed to pay $2.4 million to settle the charges. (12/15/14)
  • Stephen Timms and Yasser Ramahi (FLIR) - SEC charged two former employees in the Dubai office of Oregon-based defense contractor FLIR Systems with violating the FCPA by taking government officials in Saudi Arabia on a “world tour” to help secure business for the company. The two employees later falsified records in an attempt to hide their misconduct. Both agreed to settle the charges and pay penalties. (11/17/14)
  • Bio-Rad Laboratories - SEC charged the California-based clinical diagnostic and life science research company with violating the FCPA when its subsidiaries made improper payments to foreign officials in Russia, Vietnam, and Thailand in order to win business. (11/3/14)
  • Layne Christensen Company - SEC charged the Texas-based water management, construction, and drilling company with violating the FCPA by making improper payments to foreign officials in several African countries in order to obtain beneficial treatment and reduce its tax liability. (10/27/14)
  • Smith & Wesson - SEC charged the Springfield, Mass.-based firearms manufacturer with violating the FCPA when employees and representatives authorized and made improper payments to foreign officials while trying to win contracts to supply products to military and law enforcement overseas. (7/28/14)
  • Hewlett-Packard - SEC charged the Palo Alto, Calif.-based technology company with violating the FCPA when subsidiaries in three countries made improper payments to government officials to obtain or retain lucrative public contracts. H-P agreed to pay $108 million to settle the SEC charges and a parallel criminal case. (4/9/14)
  • Alcoa - SEC charged the global aluminum producer with violating the FCPA when its subsidiaries repeatedly paid bribes to government officials in Bahrain to maintain a key source of business. Alcoa agreed to pay $384 million to settle the SEC charges and a parallel criminal case. (1/9/14)

2013

  • Archer-Daniels-Midland Co. - SEC charged the Illinois-based global food processor for failing to prevent illicit payments made by foreign subsidiaries to Ukrainian government officials in violation of the FCPA. ADM agreed to pay more than $36 million to settle the SEC's charges. (12/20/13)
  • Weatherford International - SEC charged the Swiss-based oilfield services company with authorizing bribes and improper travel and entertainment for foreign officials in the Middle East and Africa to win business. Weatherford agreed to pay more than $250 million to settle cases with the SEC and other agencies. (11/26/13)
  • Stryker Corporation - SEC charged the Michigan-based medical technology company with violating the FCPA by bribing doctors and other government officials in five countries to obtain or retain business and make $7.5 million in illicit profits. Stryker agreed to pay more than $13.2 million to settle the SEC's charges. (10/24/13)
  • Diebold - SEC charged the Ohio-based manufacturer of ATMs and bank security systems with violating the FCPA by bribing officials at government-owned banks with pleasure trips to popular tourist destinations in order to illicitly win business. Diebold agreed to pay $48 million to settle SEC and Justice Department cases. (10/22/13)
  • Total S.A. - SEC charged the France-based oil and gas company for paying bribes to intermediaries of an Iranian government official who then exercised his influence to help the company obtain valuable contracts to develop oil and gas fields. Total agreed to pay $398 million to settle SEC and criminal charges. (5/29/13)
  • Ralph Lauren Corporation - SEC announced a non-prosecution agreement (NPA) with Ralph Lauren Corporation in which the company will disgorge more than $700,000 in illicit profits and interest obtained in connection with bribes paid by a subsidiary to government officials in Argentina from 2005 to 2009. (4/22/13)
  • Parker Drilling Company - SEC charged the worldwide drilling services and project management firm with violating the FCPA by authorizing improper payments to a third-party intermediary in order to entertain Nigerian officials involved in resolving the company's customs disputes. Parker Drilling agreed to pay $4 million to settle the SEC's charges. (4/16/13)
  • Koninklijke Philips Electronics - SEC charged the Netherlands-based health care company with FCPA violations related to improper payments made by employees at its Polish subsidiary to health care officials in Poland. Philips agreed to pay more than $4.5 million to settle the charges. (4/5/13)

2012

  • Eli Lilly and Company - SEC charged the Indianapolis-based pharmaceutical company for improper payments its subsidiaries made to foreign government officials to win business in Russia, Brazil, China, and Poland. Lilly agreed to pay more than $29 million to settle the charges. (12/20/12)
  • Allianz SE - SEC charged the Germany-based insurer with violating the books and records and internal controls provisions of the FCPA for improper payments to government officials in Indonesia that resulted in $5.3 million in profits. Allianz agreed to pay more than $12.3 million to settle the SEC's charges. (12/17/12)
  • Tyco International - SEC charged the Swiss-based global manufacturer with violating the FCPA when subsidiaries arranged illicit payments to foreign officials in more than a dozen countries.  Tyco agreed to pay $26 million to settle the SEC's charges and resolve a criminal matter with the Justice Department. (9/24/12)
  • Oracle - SEC charged the California-based computer technology company with violating FCPA by failing to prevent a subsidiary from secretly setting aside money off the company's books to make unauthorized payments to phony vendors in India. (8/16/12)
  • Pfizer - SEC charged the pharmaceutical company for illegal payments made by its subsidiaries to foreign officials in Bulgaria, China, Croatia, Czech Republic, Italy, Kazakhstan, Russia, and Serbia to obtain regulatory approvals, sales, and increased prescriptions for its products. Pfizer and recently acquired Wyeth LLC - charged with its own FCPA violations - agreed to pay a combined $45 million in their settlements. (8/7/12)
  • Orthofix International - SEC charged the Texas-based medical device company with violating the FCPA when a subsidiary paid routine bribes referred to as “chocolates” to Mexican officials in order to obtain lucrative sales contracts with government hospitals. (7/10/12)
  • Former Morgan Stanley executive - SEC charged Garth R. Peterson with secretly acquiring millions of dollars worth of real estate investments for himself and an influential Chinese official who in turn steered business to Morgan Stanley's funds. He agreed to a settlement in which he is permanently barred from the securities industry and must pay more than $250,000 in disgorgement and relinquish his approximately $3.4 million interest in Shanghai real estate acquired in his scheme. (4/25/12)
  • Biomet - SEC charged the Warsaw, Ind.-based medical device company with violating the FCPA when its subsidiaries and agents bribed public doctors in Argentina, Brazil, and China for nearly a decade to win business. (3/26/12)
  • Noble Corporation executives - SEC charged three oil services executives with bribing customs officials in Nigeria to obtain illicit permits for oil rigs in order to retain business under lucrative drilling contracts. (2/24/12)
  • Smith & Nephew - SEC charged the London-based medical device company with violating the FCPA when its U.S. and German subsidiaries bribed public doctors in Greece for more than a decade to win business. The company and its U.S. subsidiary agreed to pay more than $22 million to settle civil and criminal cases. (2/6/12)

2011

  • Magyar Telekom - SEC charged the largest telecommunications provider in Hungary and three of its former top executives with bribing government and political party officials in Macedonia and Montenegro. The firm and its parent company agreed to pay $95 million to settle civil and criminal charges. (12/29/11)
  • Aon Corporation - SEC charged one of the world's largest insurance brokerage firms with violations of the books and records and internal controls provisions of the FCPA. Aon agreed to pay $14.5 million to settle SEC charges and a $1.7 million criminal fine to the Department of Justice. (12/20/11)
  • Siemens executives - SEC charged seven former Siemens executives for their involvement in the company's decade-long bribery scheme to retain a $1 billion government contract to produce national identity cards for Argentine citizens. (12/13/11)
  • Watts Water Technologies and Leesen Chang – SEC charged the company and a former vice president of sales for improper payments disguised as sales commissions by its Chinese subsidiary to employees at state-owned design institutes in order to influence design specifications that favored their valve products for infrastructure products in China. (10/13/11)
  • Diageo – SEC charged one of the world's largest producers of premium alcoholic beverages for making $2.7 million in improper payments to government officials in India, Thailand, and South Korea to obtain lucrative sales and tax benefits. Diageo agreed to pay more than $16 million to settle the case. (7/27/11) [Administrative Proceeding]
  • Armor Holdings – SEC charged the Jacksonville, Fla.-based body armor supplier for illicit payments to United Nations officials to obtain contracts related to U.N. peacekeeping missions. Armor Holdings agreed to an SEC settlement of $5.7 million and a criminal fine of $10.29 million. (7/13/11)
  • Tenaris – SEC sanctioned the global manufacturer of steel pipe products for bribing Uzbekistan government officials during a bidding process to supply pipelines for transporting oil and natural gas. Tenaris agreed to pay $5.4 million under a Deferred Prosecution Agreement, and paid a $3.9 million criminal fine. (5/17/11)
  • Rockwell Automation – SEC charged the Milwaukee-based company for illicit payments made and leisure travel provided by a former subsidiary in China to state-owned enterprises that provided design engineering and technical integration services to influence contract awards. (5/3/11)
  • Johnson & Johnson – SEC charged the New Brunswick, N.J.-based pharmaceutical company for bribing public doctors in several European countries to win contracts for their products and paying kickbacks to Iraq to illegally obtain business. J&J agreed to pay $70 million to settle cases brought by the SEC and criminal authorities. (4/8/11)
  • Comverse Technology – SEC charged the New York-based company for its Israeli subsidiary's improper offshore payments to government officials in Greece. (4/7/11)
  • Ball Corporation – SEC charged the Colorado-based manufacturer of metal packaging for beverages, foods and household products for improper payments to employees of Argentina's government in order to import prohibited used machinery and export raw materials at reduced tariffs. (3/24/11) [Administrative Proceeding]
  • International Business Machines Corp. – SEC charged IBM for providing improper cash payments, gifts, and travel and entertainment to government officials in China and South Korea in order to secure the sale of IBM products. IBM agreed to pay $10 million to settle the SEC's charges. (3/18/11)
  • Tyson Foods – SEC charged the worldwide chicken manufacturer for making illicit payments to two Mexican government veterinarians responsible for certifying its Mexican subsidiary's chicken products for export sales. Tyson Foods agreed to pay $5 million to settle SEC and criminal charges. (2/10/11)
  • Maxwell Technologies – SEC charged the energy-related products manufacturer for making repeated bribes to Chinese government officials to obtain business from several state-owned entities. San Diego-based Maxwell agreed to an SEC settlement of more than $6.3 million as well as an $8 million criminal penalty. (1/31/11)
  • Paul W. Jennings (Innospec) – SEC charged the CEO of Innospec for approving bribes paid to government officials in Iraq and Indonesia. (1/24/11)

2010

  • Alcatel-Lucent – SEC charged the Paris-based telecommunications company for using consultants who performed little or no legitimate work to funnel bribes to government officials and win contracts in Latin America and Asia. Alcatel agreed to pay $137 million to settle SEC and Department of Justice charges. (12/27/10)
  • RAE Systems – SEC charged San Jose-based company for making improper payments to Chinese officials through two of its Chinese joint venture entities in order to obtain significant government contracts for sale of gas and chemical detection products. (12/10/10)
  • Seven Oil Services and Freight Forwarding Companies – The SEC charged Panalpina, Pride International, Tidewater, Transocean, GlobalSantaFe Corp., Noble Corporation, and Royal Dutch Shell plc with widespread bribery of customs officials in more than 10 countries to receive preferential treatment and improper benefits during the customs process. (11/4/10) [Administrative Proceeding]
  • ABB Ltd. – SEC charged the Swiss-based global provider of power and automation products for using a U.S. subsidiary to pay bribes to officials at Mexico's largest power company as well as to pay kickbacks to Iraq to obtain contracts under the U.N. Oil for Food Program. ABB agreed to a $39.3 million settlement. (9/29/10)
  • Alliance One and Universal Corporation – SEC charged two global tobacco companies for making more than $5 million in secret payments to curry favor with government officials in Thailand and around the world to illicitly obtain tobacco sales contracts. The companies paid $28.3 million to settle SEC and criminal charges. (8/6/10)
  • Joe Summers (Pride International) – SEC charged a former manager at one of the world's largest offshore drilling companies for authorizing bribes to government officials in Venezuela to extend drilling contracts and secure difficult-to-obtain receivables from the government following widespread strikes and civil unrest. (8/5/10)
  • David P. Turner and Ousama Naaman (Innospec) – SEC charged a former business director at Innospec and the company's third-party agent in Iraq for engaging in widespread bribery of Iraqi government officials to land contracts under the U.N. Oil-for-Food Program. (8/5/10)
  • General Electric, Ionics Inc., and Amersham plc – SEC charged GE and two subsidiaries for illegal kickback payments made in the form of cash, computer equipment, medical supplies, and services to the Iraqi government in order to obtain U.N. Oil for Food Program contracts. GE paid $23 million to settle the charges. (7/27/10)
  • ENI and Snamprogetti Netherlands BV – SEC charged an Italian company and its former Dutch subsidiary in a decade-long bribery scheme that included deliveries of cash-filled briefcases and vehicles to Nigerian government officials to win construction contracts. Snamprogetti and ENI jointly paid $365 million to settle SEC and criminal charges. (7/7/10)
  • Veraz Networks – SEC charged the California-based telecommunications company for improper gifts and payments made to foreign officials in China and Vietnam to win business shortly after the company went public. (6/29/10)
  • Technip SA – SEC charged the Paris-based global engineering company for bribing Nigerian government officials over a 10-year period in order to win construction contracts worth more than $6 billion. Technip agreed to pay $338 million to settle SEC and criminal charges. (6/28/10)
  • Elkin, Myers, Reynolds, Williams (Alliance One) – SEC charged four former executives and employees at the global tobacco company now named Alliance One International for their involvement in the payment of bribes to government officials in Kyrgyzstan and Thailand. (4/28/10)
  • DaimlerChrysler AG – SEC charged the Stuttgart, Germany-based automobile manufacturer for its repeated and systematic practice of paying bribes to foreign government officials to secure business in Asia, Africa, Eastern Europe, and the Middle East. Daimler paid $185 million to settle SEC and criminal charges. (4/1/10)
  • Innospec Inc. – SEC charged the specialty chemical company for its widespread bribery of foreign government officials in Iraq and Indonesia to obtain and retain business. Innospec agreed to a $40.2 million global settlement with the SEC and other agencies in the U.S. and U.K. (3/18/10)
  • NATCO Group Inc. – SEC charged the Houston-based oil field services provider for the misconduct of a subsidiary in creating and accepting false documents while paying extorted immigration fines and obtaining immigration visas in Kazakhstan. (1/11/10) [Administrative Proceeding]

Previous Years

2009

2008

2007

2006

2005

2004

2003

2002

2001

2000

  • IBM - 12/21/00

1997

1996

1986

  • Ashland Oil Inc. and Orin E. Atkins (86-cv-1904)(D.D.C. 7/8/86)

1981

  • Sam P. Wallace Co. Inc., Robert Buckner and Alfonso Rodriguez (81-cv-1915)(D.D.C. 8/13/81)

1980

  • Tesoro Petroleum Corp. (80-cv-2961) (D.D.C. 11/20/80)

1979

  • International Systems & Controls Corporation (79-cv-1760) (D.D.C. 7/9/79)

1978

  • Katy Industries, Inc., Wallace Carroll and Melvan Jacobs (78-cv-03476)(N.D. Ill. 8/30/78)
  • Page Airways, Inc., James Wilmot, Gerald Wilmot, Douglas Juston, Ross Chapin, James Lawler, and T. Richard Olney (78-cv-0656) (D.D.C. 4/11/78)

Last Reviewed or Updated: Oct. 17, 2024