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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