This graphic identifies the ten largest total bribery payments alleged in groups of related Enforcement Actions initiated since the statute's enactment. Bribery payments 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. Offers or promises to pay bribes that are not actually paid are excluded from the total to the extent they can 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 definitions of "Enforcement Action" and "FCPA Matter."