About Largest Sanction to Bribe Ratio

This graphic identifies the ten largest sanction to bribe ratios in groups of related Enforcement Actions initiated since the statute's enactment. The sanction to bribe ratio represents the total sanctions imposed in a group of related Enforcement Actions as a percentage of the completed bribery payments. Bribery payments and sanctions are culled from Enforcement Actions linked to an FCPA Matter and are adjusted to avoid double counting that could otherwise occur when, for example, the same or affiliated defendants are sued in different Enforcement Actions for the same underlying bribery scheme. FCPA Matters with only Investigations are excluded from this analysis. Sanctions paid to foreign governments pursuant to global resolutions are excluded from this analysis. See About Us - Datasets for definitions of "Enforcement Action" and "FCPA Matter."