Enforcement At The Century’s Dawn

The years 2000 through 2005 are already ancient FCPA history. There were just fifteen cases and all but two penalties were under $5 million.

Speaking of penalties, disgorgement first appeared in an FCPA case in 2004. ABB Ltd paid the SEC $5.9 million in disgorged profits to settle civil anti bribery, books-and-records, and internal-controls offenses.

Here’s the record:

In 2005, 5 companies paid $36.3 million.

DPC — $4.8 million

Invision — $1.1 million

Micrus — $450,000

Monsanto — $1.5 million

Titan — $28.5 million

In 2004, 3 companies paid $16.4 million.

ABB — $15.9 million

B.J. Services — nil

Schering-Plough — $500,000

In 2003, 0 companies paid nil.

In 2002, 2 companies paid $2.6 million.

BellSouth — $150,000

Syncor — $2.5 million

In 2001, 4 companies paid $175,000.

American Bank Note Holographics — $75,000

Baker Hughes — nil

Chiquita Brands International — $100,000

KPMG Siddharta Siddharta & Harsono — nil

In 2000, 1 company paid $300,000.

IBM — $300,000


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