In spite of an upturn in FCPA foreign corruption anti-bribery enforcement activities, economic and shareholder-value concerns are still expected to pressure companies to look abroad for their cost-cutting and market growth opportunities.
Aggressive Enforcement of FCPA Anti-Bribery Violations is a 'Sleep Well' Risk
Civil and criminal penalties for violations of the FCPA Anti-bribery and Books and Records violations are significant:
The SEC and DOJ have become far more aggressive with FCPA enforcement—greatly increasing both corporate risk and regulatory pressures. The Top 10 FCPA Settlements fines add up to an eye-popping $4.6 billion.
Top 10 FCPA Settlements
Rank Company Fine
Year 1 Siemens $800,000,000.00 2008 2 Alstom $772,000,000.00 2014 3 KBR / Halliburton $579,000,000.00 2009 4 BAE $400,000,000.00 2010 5 Total SA $398,000,000.00 2013 6 VimpelCom $397,600,000.00 2016 7 Alcoa $384,000,000.00 2014 8 Snamprogetti Netherlands B.V. / ENI S.p.A $365,000,000.00 2010 9 Technip SA $338,000,000.00 2010 10 JGC Corporation $218,000,000.00 2011
One result of this increased and very public enforcement is a surge in companies seeking more robust and structured approaches to anti-bribery and other 'sleep well' risks. Many are examining their FCPA and other trade compliance programs to determine where enhancements are needed and how best to satisfy board and executive-level expectations.
Visual OFAC™ FCPA Anti-Bribery Software Solutions
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