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Top 10 settlements under the Foreign Corrupt Practices Act

Of Top 10 FCPA Settlements, 8 Involve Foreign Companies

November 5, 2010, 10:49 AM ET

By Joe Palazzolo

The FCPA Blog, a resource for anyone with an interest U.S. anti-corruption efforts, keeps a current list of the top 10 settlements (by dollar amount) under the Foreign Corrupt Practices Act.

Thursday’s announcement that Swiss freight forwarder Panalpina World Transport Ltd. and six of its customers reached settlements in a three-year-old foreign bribery investigation wreaked havoc on the list. (Click here for a list of the companies, settlement amounts, etc.)

When the dust settled, three U.S. companies — Willbros Group Inc., Chevron Corp. and Baker Hughes Inc. — were squeezed out of the top 10 by Panalpina (Switzerland, No. 7), Pride International Inc. (U.S., No. 9) and Royal Dutch Shell PLC (Netherlands, No. 10).

The shuffling means that eight of the top 10 FCPA settlements involved foreign companies. (Siemens AG, which in 2008 agreed to pay $800 million in civil and criminal penalties, tops the list.) Other than demonstrating the statute’s reach, the list is a nice promotional tool for the Justice Department and the Securities and Exchange Commission.

For years, U.S. companies complained — with good reason — that the FCPA put them at a competitive disadvantage with their foreign counterparts. Level the playing field, they said.

If the list is of no comfort in this regard, then consider this: The U.K. Bribery Act, which goes into effect in April next year, creates liability for companies with business in the U.K., even if the company is foreign and the misconduct occurred wholly outside the U.K.

The Serious Fraud Office’s chief, Richard Alderman, has said repeatedly that his agency pushed for broad jurisdiction to eliminate inequity. We’ll have to wait for the SFO’s top 10 list to see if it works.


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