|FCPA Groups||Total Bribery|
|GlobalSantaFe's Involvement in Multiple Countries from 2002 to 2007||$ 0|
|Novartis' Involvement in China from 2009 to 2013||$ 0|
|AstraZeneca's Improper Conduct in China and Russia Between 2005 and 2010||$ 0|
For each monetary range represented on the navigation bar, this heat map identifies the number of FCPA Groups filed since the statute's enactment that allege a total dollar value for total bribery payments that falls within that range. The navigation bar organizes the data by count and color, putting the bribery range with the largest number of FCPA Groups at the top in red, and the bribery range with the fewest number of FCPA Groups on the bottom in yellow. Bribery payments 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. "No bribery" means that no bribery payments were alleged in the FCPA Group. FCPA Groups for which no total bribery value is disclosed are not included on the navigation bar, but are included in the list of 204 Total FCPA Groups. See About Us - Datasets for a definition of "FCPA Group."