Siemens AG • Fine: $800M • 2008The German engineering and electronics company paid the Iraqi government $1.7 billion to win 42 contracts.

KBR/Halliburton • Fine: $579M • 2009The U.S. engineering, construction and private military contracting company paid Nigerian o�cials at least $182 million.

Daimler AG • Fine: $185M • 2010The German automotive corporation paid foreign o�cials in at least 22 countries $56 million to buy cars, amounting to more than 200 transactions.

Technip S.A. • Fine: $338M • 2010The French construction company that works with oil and gas industries paid Nigerian o�cials for construction contracts worth $6 billion over a decade’s time.

Snamprogetti Netherlands B.V. • Fine: $365M • 2010The Dutch oilfield company paid $180 million to obtain contracts to build liquefied natural gas facilities in Nigeria.

BAE Systems PLC • Fine: $400M • 2010The British defense contractor paid a Saudi Arabian o�cial $80 billion to secure the sale of fighter jets.

Panalpina • Fine: $81.5M • 2010The Swiss logistics company paid o�cials in seven countries $27 million to make customs clearance easier for its customers.

Alcatel-Lucent S.A. • Fine: $137M • 2010The French telecommunications equipment company paid foreign o�cials through sham consultants to secure business in Costa Rica, Honduras, Malaysia and Taiwan, resulting in $48.1 million in profits.

JGC Corporation • Fine: $218.8M • 2011The Japanese engineering company paid a $218.8 million fine for a scheme to bribe Nigerian government o�cials to secure engineering, procurement and construction contracts over the span of a decade.

Total S.A. • Fine: $398M • 2013The French oil and gas company paid an Iranian government o�cial at least $60 million to obtain contracts to develop oil and gas fields, which resulted in more than $150 million in profits.

Weatherford International • Fine: $152.6M • 2013The Swiss-based oilfield services company paid foreign o�cials in the Middle East and Africa with money, travel and entertainment to approve a contract renewal.

Alcoa • Fine: $384M • 2014A subsidiary of the U.S.-based aluminum manufacturer, throughan international middleman in London, bribed o�cials from Bahrain with millions of dollars to secure business in the country.

In 1977, the Foreign Corrupt Practices Act (FCPA) was introduced to make it unlawful for individuals and companies to bribe foreign o�cials. The measure focuses on the intent of the bribe rather than the amount of the bribe.

THE GENESIS

ADDING IT ALL UP: 12 NOTEWORTHY CASES

TWO CASES THAT PAVED THE WAY

LockheedFrom the late 1950s to the early 1970s, company executives paid foreign o�cials in West Germany, Italy, Japan, the Netherlands and Saudi Arabia a total of $22 millionto purchase Lockheed’s aircrafts.

BananagateUnited Brands bribed the President of Honduras with $1.25 million in 1974 and then another $1.25 million the next year to lower taxes from 50 cents to 25 cents per box of bananas.$24.8M

FINE:

$25MFINE:

The QuickHistoryof FCPA

Violations

2011

$218.8million

JGC Corporation

2014

Alcoa

$384million

2008

SiemensAG

$800million

2009

KBR/Halliburton

$579million

2010

DaimlerAG

$185million

2010

TechnipS.A.

$338million

2010

SnamprogettiNetherlands

B.V.

$365million

2010

BAESystems

PLC

$400million

2010

Panalpina

$81.5million

2010

Alcatel-LucentS.A.

$137million

TotalS.A.

2013

$398million

WeatherfordInternational

2013

$152.6million

SOURCES:

http://www.businessinsider.com/the-largest-fcpa-settlements-2012-8#a-switzerland-based- logistics-company-admitted-to-paying-27-million-in-bribes-1http://www.fcpablog.com/https://www.sec.gov/spotlight/fcpa/fcpa-cases.shtmlhttp://www.shearman.com/~/media/Files/Services/FCPA/2014/FCPADigestTPFCPA010614.pdfhttp://www.justice.gov/criminal/fraud/fcpa/http://articles.latimes.com/1995-01-28/business/fi-25231_1_egyptian-politician

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FEWER CASES, HIGHER COSTS

While there has been a decline in the number of violations related to the FCPA in recent years, it’s important to note the increase in the cost to resolve a corporate FCPA enforcement action in 2013. Not one of the nine corporate FCPA enforcement actions in 2013 settled for less than $1 million when the fines from the SEC and DOJ are aggregated. In fact, only two cases were settled for less than eight figures. To find the most recentexample where a company paid less than a six-figure FCPA settlement, you’d have to go all the way back to the March 2011 settlement between Ball Corp. and the SEC.

2010

23cases

$1.78billion

2011

16cases

$508.6million

2012

12cases

$259.4million

2013

9cases

$720million