Fifteen companies settled FCPA enforcement actions in 2011 by paying a total of $508.6 million.
(In 2010, 23 companies paid $1.8 billion. In 2009, 11 companies paid $644 million. In 2008, 11 companies paid $890.)
Three cases this year made it into the top ten — JGC, Magyar Telekom, and Johnson & Johnson. J&J also left the list before the year ended.
While 2011 was slower on the corporate side, it was busy for individuals in all categories — indictments, trials, sentences, dismissals, mistrials, and appeals.
The 2011 FCPA enforcement index looks like this:
Organizations (countries involved) U.S. enforcement agencies / financial penalties including fines, disgorgement, and interest:
Aon Corporation (Costa Rica, Egypt, Vietnam, Indonesia, the United Arab Emirates, Myanmar, and Bangladesh) DOJ, SEC / $16.2 million
Armor Holdings Inc. (United Nations contracts) DOJ, SEC / $16 million
Ball Corporation (Argentina) SEC / $300,000
Bridgestone Corporation (Mexico) DOJ / $28 million for antitrust and FCPA violations; FCPA component was $22 million
Comverse Technology Inc. (Greece) DOJ, SEC / $2.8 million
Diageo plc (India, Thailand, South Korea) SEC / $16.4 million
IBM (South Korea and China) SEC / $10 million
JGC Corporation (Nigeria) DOJ / $218.8 million
Johnson & Johnson (Greece, Poland, Romania, United Nations Oil for Food Program) DOJ, SEC / $70 million
Lindsey Manufacturing (Mexico) DOJ, indictment dismissed by judge after jury trial and conviction, because of prosecutorial misconduct
Magyar Telecom and majority owner Deutsche Telekom (Macedonia, Montenegro) DOJ, SEC / $95 million
Maxwell Technologies Inc. (China) DOJ, SEC / $14.3 million
Rockwell Automation Inc. (China) SEC / $2.8 million
Tenaris (Uzbekistan) SEC / $9 million
Tyson Foods Inc. (Mexico) DOJ, SEC / $5.2 million
Watts Water Technologies, Inc. (China) SEC / $3.7 million
Individuals indicted, tried, or sentenced (includes cases of money-laundering only in FCPA-related actions):
Angela Aguilar (Lindsey Manufacturing) DOJ, money-laundering conviction vacated after dismissal of indictments against Lindsey and Lee defendants.
Daniel Alvirez (Africa sting) DOJ, pleaded guilty to two counts of conspiracy to violate the FCPA, sentencing pending
Andras Balogh (Magyar Telekom) SEC, charged in civil complaint
Andrew Bigelow (Africa sting) DOJ, criminal trial ended in mistrial
Ulrich Bock (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
Frederic Bourke (Azerbaijan privatization) DOJ, lost appeal and motion for new trial, will now serve year-and-a-day prison sentence and pay $1 million criminal fine
Manuel Caceres (Latin Node Inc.) pleaded guilty to conspiracy to violate the FCPA, sentencing pending
Leesen Chang (Watts Water Technologies, Inc.) SEC, administrative order, $25,000 penalty
Washington Vasconez Cruz (Cinergy Telecommunications Inc.) DOJ, charged with one count of conspiracy to violate the FCPA and to commit wire fraud, six counts of FCPA violations, one count of conspiracy to commit money laundering, and 19 counts of money laundering
Miguel Czysch (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
Joel Esquenazi (Terra Telecommunications Corp.) DOJ, convicted in criminal trial, sentenced to 15 years in prison
Haim Geri (Africa sting) DOJ, pleaded guilty to one count of conspiracy to violate the Foreign Corrupt Practices Act, sentencing pending
Stephen G. Giordanella (Africa sting) DOJ, acquitted after judge dismissed conspiracy count, the only charge the defendant faced
Jorge Granados (Latin Node Inc.) DOJ, sentenced to 46 months in prison
Paul W. Jennings (Innospec Inc.) SEC, $300,000
Steve K. Lee (Lindsey Manufacturing) DOJ, indictment dismissed by judge after jury trial AND conviction, because of prosecutorial misconduct
Keith Lindsey (Lindsey Manufacturing) DOJ, indictment dismissed by judge after jury trial AND conviction, because of prosecutorial misconduct
Tamas Morvai (Magyar Telekom) SEC, charged in civil complaint
Ousama Naaman (Innospec) DOJ / SEC sentenced to thirty months in federal prison and fined $250,000 after guilty plea
Pankesh Patel (Africa sting) DOJ, criminal trial ended in mistrial
Antonio Perez (Terra Telecommunications Corp.) DOJ, sentenced to two years in prison and ordered to forfeit $36,375
Bernd Regendantz (Siemens) SEC, settled civil charges by paying a civil penalty of $40,000
Eberhard Reichert (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
Flavio Ricotti (Control Components Inc.) pleaded guilty to a single count of conspiracy to violate the Foreign Corrupt Practices Act and the Travel Act, sentencing pending
Amadeus Richers (Cinergy Telecommunications Inc.) DOJ, charged with one count of conspiracy to violate the FCPA and to commit wire fraud, six counts of FCPA violations, one count of conspiracy to commit money laundering, and 19 counts of money laundering
Carlos Rodriguez (Terra Telecommunications Corp.) DOJ, convicted in criminal trial, sentenced to 7 years in prison
Manuel Salvoch ( Latin Node Inc.) DOJ, pleaded guilty to one count of conspiracy to violate the FCPA, sentencing pending
Carlos Sergi (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
Uriel Sharef (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
Stephan Signer (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
Leo Winston Smith (Pacific Consolidated Industries) DOJ, sentenced in December 2010, sentence disclosed January 2011, six months in prison followed by six months of home confinement
Jonathan Spiller (Africa sting) DOJ, pleaded guilty to one count of conspiracy to violate the FCPA, sentencing pending
Herbert Steffen (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
Elek Straub (Magyar Telekom) SEC, charged in civil complaint
Jeffrey Tesler (KBR and TSKJ consortium agent) DOJ, pleaded guilty to one count of conspiracy and one count of violating the FCPA, Tesler agreed to forfeit $149 million, final sentencing pending
Lee Allen Tolleson (Africa sting) DOJ, criminal trial ended in mistrial
Andres Truppel (Siemens) DOJ, SEC, criminal and civil charges including conspiracy and substantive FCPA offenses, money-laundering, and wire fraud
John Benson Weir (Africa sting) DOJ, criminal trial ended in mistrial
