Enforcement of the Foreign Corrupt Practices Act (FCPA) continues to be a high priority area for the SEC. In 2010, the SEC's Enforcement Division created a specialized unit to further enhance its enforcement of the FCPA, which prohibits companies issuing stock in the U.S. from bribing foreign officials for government contracts and other business.

The following is a list of the SEC's FCPA enforcement actions listed by calendar year:

2022

  • Honeywell International Inc. -- The company agreed to pay more than $81 million to settle the SEC’s charges that it violated the anti-bribery, books and records, and international accounting violations of the FCPA arising out of bribery schemes in Brazil and Algeria. In 2010, Honeywell offered at least $4 million in bribes to a high-ranking Brazilian government official in connection with the bidding process at Petrobras, Brazil’s state-owned oil company. In 2011, employees and agents of Honeywell’s Belgian subsidiary paid more than $75,000 in bribes to an Algerian government official to obtain and retain business with the Algerian state-owned entity Sonatrach. The SEC’s Order provides for an offset of up to $38.7 million of payments made to the Brazilian government to settle charges relating to the Brazilian bribery scheme. (12/19/22).

  • ABB -- A Switzerland-based global electrification and automation company was ordered to pay more than $147 million to resolve charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with a bribery scheme in South Africa; specifically, $75 million in a civil monetary penalty, $58 million in disgorgement and over $14.5 million in prejudgment interest. Payment of the penalty and prejudgment interest were deemed satisfied by an earlier payment of ill-gotten gain to the government of South Africa. (12/3/22).

  • Oracle Corporation – The company agreed to pay more than $23 million to settle charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with violations at its subsidiaries in Turkey, the United Arab Emirates, and India. (9/27/22).

  • Gol Intelligent Airlines Inc. – The second largest carrier in Brazil agreed to pay more than $160 million to the SEC, DOJ, and Brazilian authorities to resolve anti-bribery, books and records, internal accounting controls, and other related charges, for its involvement in a bribery scheme that a senior executive orchestrated. The U.S. authorities waived all but $41.5 million due to its inability to pay. (9/15/22)
  • Tenaris -- A Luxembourg-based global manufacturer and supplier of steel pipe products, agreed to pay more than $78 million to resolve charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with a bribery scheme involving its Brazilian subsidiary.  (6/2/22)
  • Stericycle, Inc. – A leading provider of medical waste and other services agreed to pay more than $28 million to settle SEC charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with violations at its subsidiaries in Argentina, Brazil, and Mexico. (4/20/22)
  • KT Corporation -- The largest South Korean Telecommunications company agreed to pay more than $6.3 million to settle charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with improper payments for the benefit of government officials in Korea and Vietnam.  (2/17/2022)

2021

  • Credit Suisse --  The firm agreed to pay nearly $100 million in disgorgement, PJI and penalty to settle charges that it violated the anti-fraud provisions of the federal securities laws and the books and records and internal accounting controls provisions of the FCPA in connection with its role in three financial transactions on behalf of Mozambican state-owned entities. See related action VTB Capital.  (10/19/21)
  • WPP plc – The world’s largest advertising group agreed to pay more than $19 million to settle charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with violations at its subsidiaries in India, Brazil, China, and Peru. (9/24/21)
  • Amec Foster Wheeler Ltd. -- The company agreed to pay $22.7 million to settle SEC charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with a scheme to obtain an oil and gas engineering and design contract from the Brazilian state-owned oil company, Petroleo Brasileiro S.A. (6/25/21)
  • Asante Berko - SEC charged a former executive of a financial services company with orchestrating a bribery scheme to help a client to win a government contract to build and operate an electrical power plant in the Republic of Ghana. See Litigation Release for Final Judgment. (6/23/21)
  • Deutsche Bank AG - The firm agreed to pay more than $43 million in disgorgement and PJI to settle charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with improper payments to intermediaries in China, the UAE, Italy and Saudi Arabia. (1/8/21)

2020

  • Goldman Sachs Group, Inc. - The firm agreed to pay more than more than $1 billion to settle SEC charges that it violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA in connection with the 1Malaysia Development Berhad (1MDB) bribe scheme. See related action against Tim Leissner (10/22/20).
  • J&F Investimentos, S.A. - Brazilian nationals Joesley Batista and Wesley Batista and their companies J&F Investimentos S.A. and JBS S.A., a global meat and protein producer, have agreed to pay nearly $27 million to resolve charges that they caused Pilgrim’s Pride’s violations of the books and records and internal accounting controls provisions of the FCPA. The Batistas also agreed to each pay a $550,000 civil penalty. The parties also agreed to a three-year self-reporting undertaking. (10/14/20)
  • Herbalife Nutrition, Ltd. - The Los Angeles-based direct selling company agreed to pay more than $67 million to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA arising out of a bribery scheme orchestrated by its China subsidiary. See related action against Jerry Li. (9/28/20)
  • World Acceptance Corp. (“WAC”) - Without admitting or denying the SEC’s findings, WAC settled to anti-bribery, books and records, and internal accounting controls provisions of the FCPA and paid over $20 million to resolve charges arising out of a bribery scheme orchestrated by its former Mexican subsidiary. (8/6/2020)
  • Alexion Pharmaceuticals - Boston-based pharmaceutical company Alexion Pharmaceuticals Inc. agreed to pay more than $21 million to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA. (7/2/20)
  • Novartis AG - Global pharmaceutical and healthcare company and its former Alcon subsidiary agreed to pay over $340 million to resolve SEC and DOJ charges arising out of conduct in multiple jurisdictions. (6/25/20)
  • ENI S.p.A. - Italian multinational oil and gas company agreed to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with an improper payment scheme in Algeria. (4/17/20)
  • Cardinal Health - Ohio-based pharmaceutical company Cardinal Health, Inc. agreed to pay more than $8 million to resolve charges that it violated the books and records and internal accounting controls provisions of the FCPA in connection with its operations in China. (2/28/20)

2019

  • Tim Leissner - A former executive of Goldman Sachs Group Inc. agreed to a settlement with the SEC that includes a permanent bar from the securities industry for violating the FCPA by engaging in a corruption scheme, by which he obtained millions of dollars by paying unlawful bribes to various government officials to secure lucrative contracts for Goldman Sachs. (12/16/19).
  • Ericsson – The multinational telecommunications company agreed to pay more than $1 billion to the SEC and DOJ to resolve charges that it violated the FCPA by engaging in a large-scale bribery scheme involving the use of sham consultants to secretly funnel money to government officials in multiple countries. (12/6/19)
  • Jerry Li – SEC charged Jerry Li, a Chinese national and former managing director of the Chinese subsidiary of a U.S.-based direct selling company listed on the NYSE, for bribing government officials in China to obtain direct selling licenses made through payments of cash, gifts, travel, meals and entertainment. (11/15/19)
  • Westport and Nancy Gougarty – SEC charged this Canadian issuer and its former CEO Gougarty with bribing a Chinese government official in violation of the FCPA along with related violations of the books and records and internal accounting controls provisions. Westport and Gougarty agreed to pay more than $4.1 million to settle the charges. (9/27/19)
  • Barclays – The UK-based bank agreed to pay $6.3 million to settle violations of the internal accounting controls and recordkeeping provisions in connection with its hiring practices in Asia. (9/27/19)
  • Quad/Graphics, Inc. – the marketing solutions and printing service provider agreed to pay nearly $10,000,000 to resolve charges that it violated the FCPA by engaging in multiple bribery schemes in Peru and China, and creating false records to conceal commercial transactions with a state-controlled Cuban telecommunications company that were subject to U.S. sanctions and export controls laws. (9/26/19)
  • TechnipFMC plc – The global oil and gas services company agreed to pay more than $5 million to resolve violations of the FCPA’s anti-bribery, internal accounting controls and recordkeeping provisions by FMC Technologies prior to its 2017 merger with Technip.S.A. for conduct related to Iraq. (9/19/19)
  • Sridhar Thiruvengadam – agreed to settle charges relating to his role in a bribery scheme while serving as chief operating officer of Cognizant, a New Jersey-based technology company. (9/13/19) See related actions against Cognizant (2/15/19) and Coburn and Schwartz. (2/15/19)
  • Juniper Networks – The California-based telecommunications company agreed to pay more than $11.7 million to resolve violations of the FPCA's internal accounting controls and recordkeeping provisions in China and Russia. (8/29/19)
  • Deutsche Bank AG – Deutsche Bank AG agreed to pay more than $16 million to resolve violations of the FCPA's internal accounting controls and recordkeeping provisions in connection with its hiring practices. (8/22/19)
  • Microsoft Corporation – The company agreed to pay more than $24 million to settle SEC charges related to FCPA violations in Hungary, Thailand, Saudi Arabia and Turkey and criminal charges related to Hungary. (7/22/19)
  • Walmart Inc. – SEC charged Walmart with violating the books and records and internal accounting controls provisions of the FCPA by failing to operate a sufficient anti-corruption compliance program for more than a decade as the retailer experienced rapid international growth. Walmart agreed to pay more than $144 million to settle the SEC’s charges and approximately $138 million to resolve parallel criminal charges by the DOJ for a combined total of more than $282 million. (6/20/19)
  • Telefônica Brasil S.A. – SEC charged telecommunications company Telefônica Brasil with violating the accounting provisions of the FCPA when it sponsored the attendance of government officials at the World Cup and Confederations Cup. Telefônica Brasil agreed to pay a $4,125,000 penalty to settle the case. (5/9/19)
  • Fresenius Medical Care AG & Co. – the German based provider of products and services for individuals with chronic kidney failure has agreed to pay $231 million to the SEC and Department of Justice in a global settlement to resolve violations of the FCPA in multiple countries over the course of nearly a decade. (3/29/19)
  • Mobile TeleSystems PJSC – the Russian-based telecommunications provider agreed to pay $850 million in a global settlement to resolve violations of the FCPA to win business in Uzbekistan. (3/6/19)
  • Cognizant – The New Jersey-based technology company agreed to pay $25 million to settle violations of the anti-bribery, internal accounting controls, and recordkeeping provisions. (2/15/19)
  • Gordon Coburn and Steven E. Schwartz – the former Cognizant officials were charged with authorizing $2.5 million in bribe payments to a government official in India. (2/15/19)

2018

  • Polycom – The San Jose-based provider of communications products has agreed to pay more than $16 million to settle charges that its Chinese subsidiary facilitated improper payments to government officials (12/26/18)
  • Centrais Elétricas Brasileiras S.A. – The Brazil-based power generation, transmission, and distribution company agreed to pay a $2.5 million penalty for violating the accounting provisions of the FCPA after former officers at its subsidiary engaged in a bribery scheme involving the construction of a nuclear power plant. (12/26/18)
  • Paul A. Margis and Takeshi “Tyrone” Uonaga – The former senior executives of the U.S. subsidiary of Panasonic Corp. agreed to pay penalties for knowingly violating the books and records and internal accounting controls provisions. NOTE: Panasonic settled charges in April 2018. (12/18/18)
  • Vantage Drilling International – The Houston-based offshore drilling company agreed to pay $5 million to settle charges that its predecessor violated internal accounting controls provisions. (11/19/18)
  • Stryker Corp. – The Michigan-based medical device company agreed to pay a $7.8 million penalty for insufficient internal accounting controls and inaccurate books and records. (9/28/18)
  • Petróleo Brasileiro S.A. – The Brazil-based oil-and-gas company agreed to pay $1.78 billion in a global resolution arising out of a massive bribery and bid-rigging scheme. (9/27/18)
  • Patricio Contesse González – Agreed to pay $125,000 to resolve charges that he violated the FCPA while serving as CEO of Chilean-based chemical and mining company Sociedad Química y Minera de Chile S.A. (9/25/18)
  • United Technologies – The Connecticut-based company agreed to pay nearly $14 million to settle charges that it made illicit payments to facilitate sales of elevators and aircraft engines. (9/12/18)
  • Joohyun Bahn – A New Jersey-based real estate broker agreed to settle charges that he attempted to bribe a foreign official while brokering the sale of a high-rise commercial building on behalf of a foreign private issuer. (9/6/18)
  • Sanofi – Agreed to pay more than $25 million to resolve charges related to corrupt payments to win business in Kazakhstan and the Middle East. (9/4/18)
  • Legg Mason – Agreed to pay more than $34 million to settle charges related to a scheme to bribe Libyan government officials. (8/27/18)
  • Credit Suisse Group AG – Agreed to pay more than $30 million to the SEC and a $47 million criminal penalty to resolve charges that the firm obtained investment banking business in the Asia-Pacific region by corruptly influencing foreign officials in violation of the FCPA. (7/5/18)
  • Beam Suntory Inc.–Agreed to pay more than $8 million to resolve charges that its Indian subsidiary violated the FCPA by using third-party distributors to make illicit payments to increase sales orders, process licensing registrations, and acquire non-public data. (7/2/2018)
  • Panasonic Corp. – The Japan-based company agreed to pay more than $143 million to resolve FCPA charges involving a lucrative consulting position it offered to a government official at a state-owned airline to induce the official to help its U.S. subsidiary in obtaining and retaining business from the airline. (4/30/18)
  • The Dun & Bradstreet Corp. – The company agreed to pay more than $9 million in disgorgement, interest and a civil penalty to resolve FCPA violations stemming from improper payments made by two Chinese subsidiaries. (4/23/18)
  • Kinross Gold – The Canada-based gold mining company agreed to pay a $950,000 penalty to resolve FCPA violations arising from its repeated failure to implement adequate accounting controls of two subsidiaries in Africa. (3/26/18)
  • Elbit Imaging – The Israel-based company agreed to pay a $500,000 penalty to resolve FCPA violations stemming from payments to consultants for purported services related to a real estate development project in Romania. (3/9/18)

2017

  • Telia – The Sweden-based telecommunications provider agreed to pay $965 million in a global settlement to resolve violations of the FCPA to win business in Uzbekistan. (9/21/17)
  • Alere, Inc. – A Massachusetts-based medical manufacturer has agreed to pay more than $13 million to settle charges that it committed accounting fraud through its subsidiaries to meet revenue targets and made improper payments to foreign officials to increase sales in certain countries. (9/28/2017)
  • Halliburton – The company agreed to pay $29.2 million and a former vice president agreed to pay a $75,000 penalty to settle charges related to payments made to a local company in Angola in the course of winning lucrative oilfield services contracts. (7/27/17)
  • Michael L. Cohen and Vanja Baros – The former Och-Ziff executives were charged with being the driving forces behind a far-reaching bribery scheme that paid tens of millions of dollars in bribes to high-level government officials in Africa. (1/26/17)  NOTE: Och-Ziff and other executives settled charges in 2016.
  • Orthofix International – The Texas-based medical device company agreed to pay more than $6 million to settle charges that its subsidiary in Brazil used high discounts and improper payments to induce doctors under government employment to use Orthofix products. (1/18/17)
  • SQM - Chilean-based chemical and mining company Sociedad Quimica y Minera de Chile S.A. agreed to pay more than $30 million to resolve parallel civil and criminal cases finding that it violated the FCPA by making improper payments to Chilean political figures and others. (1/13/17)
  • Biomet - The Warsaw, Ind.-based medical device manufacturer agreed to pay more than $30 million to resolve SEC and Justice Department investigations into the company's anti-bribery violations in Brazil and Mexico. (1/12/17)
  • Cadbury Limited/Mondelez International - The global snacking business agreed to pay a $13 million penalty for FCPA violations occurring after Mondelez (then Kraft Foods Inc.) acquired Cadbury and its subsidiaries, including one in India that proceeded to make illicit payments to obtain government licenses and approvals for a chocolate factory in Baddi. (1/6/17)