|Groups of Related Enforcement Actions||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|
|Guralp Systems' Involvement in South Korea between 2009 and 2015||$ 0|
For each bribery range represented on the navigation bar, this heat map identifies the number of groups of related Enforcement Actions filed since the statute's enactment that allege a 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 most groups of related Enforcement Actions at the top in red, and the bribery range with the fewest groups of related Enforcement Actions on the bottom in yellow. Bribery payments are culled from Enforcement Actions linked to FCPA Matters 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 misconduct. Bribery payments referenced in FCPA-related Investigations are excluded from this analysis. 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 Enforcement Actions. Enforcement Actions for which bribery is alleged but no total bribery value is disclosed are not included on the navigation bar, but are included in the list of Total Related Enforcement Actions. See About Us - Datasets for the definition of "Enforcement Action."