The New FCPA Top 5 Settlements

This U.S. Thanksgiving holiday, we are looking back at the five largest FCPA corporate settlements measured by total penalties and disgorgements as assessed by U.S. enforcement authorities. Two of them – Goldman Sachs and Airbus – were concluded in 2020, and, at a recent ABA program, DOJ Fraud Section chief Dan Kahn called 2020 “one of the high points of Fraud Section history in terms of white collar enforcement.” This year, with its 11 corporate settlements, is the leader in FCPA penalty and disgorgement totals since the law’s enactment in 1977, drastically reshaping the top five rankings. This special issue brings together our analysis of each of those cases – Goldman Sachs, Airbus, Petrobras, Ericsson and Telia. We will return to our regular bi-weekly publication schedule on December 2.

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