This graphic identifies the ten largest total bribery payments made in violation of the FCPA, as alleged in FCPA-related Enforcement Actions. Data was culled from all FCPA-related Enforcement Actions filed since the statute's enactment. Offers or promises to pay bribes that were not actually paid were excluded from the totals to the extent they could be segregated. Bribery totals include all completed bribery payments that allegedly violate any provision of the FCPA (including bribery payments that are made to private individuals in violation of the books and records or internal controls provisions of the FCPA). The data used to generate this graphic were culled from publicly available documents filed in connection with the Enforcement Actions, and may not reflect all bribery payments that were offered or made. See About Us - Datasets for a definition of "Enforcement Action."
Users can click on the name of the Enforcement Action to access the case information page for that particular action.