| Groups of Related Enforcement Actions | Total Bribery |
|---|---|
| Goldman Sachs' Involvement in Malaysia and the U.A.E. between 2009 and 2014 | $ 1,607,700,000 |
| Siemens' Involvement in Multiple Countries from 1996 to 2007 | $ 1,400,000,000 |
| Petroleo Brasileiro S.A. - Petrobras' Involvement in Brazil between 2003 and 2012 | $ 1,000,000,000 |
| Gorrin's Involvement in Venezuela between 2008 and 2017 | $ 1,000,000,000 |
| Multiple Companies' Involvement in Uzbekistan between 2004 and 2012 | $ 866,000,000 |
| Odebrecht and Braskem's Involvement in Multiple Countries from 2001 to 2016 | $ 788,000,000 |
| Multiple Parties' Involvement in Venezuela between 2011 and 2020 | $ 600,000,000 |
| Mobile Telesystems PJSC's Involvement in Uzbekistan between 2004 and 2012 | $ 420,825,848 |
| Montedison's Involvement in Italy in 1998 | $ 378,000,000 |
| Telia's Involvement in Eurasia between 2007 and 2012 | $ 331,200,000 |
| Azure Power Global and Adani Green's Involvement in India between 2020 and 2024 | $ 250,000,000 |
| BAE Systems' Involvement in Czech Republik, Hungary, and Saudi Arabia in 2000 | $ 228,500,000 |
| TSKJ's Involvement in Nigeria from 1994 to 2004 | $ 183,000,000 |
| SBM Offshore's Involvement in Multiple Countries | $ 180,000,000 |
| J&F Investimentos' Involvement in Brazil between 2005 and 2017 | $ 177,600,000 |
| Credit Suisse's Involvement in Mozambique between 2013 and 2017 | $ 150,000,000 |
| Ericsson's Involvement in Multiple Countries between 2000 and 2017 | $ 149,950,000 |
| VimpelCom's Involvement in Uzbekistan between 2006 and 2012 | $ 114,000,000 |
| Alcoa Subsidiaries' Involvement in Bahrain between 1989 and 2009 | $ 111,200,000 |
| Omega Advisors' Involvement in Azerbaijan in 1997 | $ 100,000,000 |
| Glencore's Involvement in Multiple Countries between 2007 and 2018 | $ 100,000,000 |
| Gunvor's Involvement in Ecuador between 2012 and 2020 | $ 97,000,000 |
| Societe Generale and Legg Mason's Involvement in Libya between 2004 and 2011 | $ 90,740,000 |
| Mercator's Involvement in Kazakhstan in 1995 | $ 84,000,000 |
| Alstom and Marubeni's Involvement in Multiple Countries from 2000 to 2010 | $ 75,000,000 |
| Las Vegas Sands' Involvement in China from 2006 to 2011 | $ 62,000,000 |
| Total's Involvement in Iran from 1995 to 2005 | $ 60,000,000 |
| Daimler's Involvement in Multiple Countries between 1998 and 2008 | $ 56,000,000 |
| Keppel Offshore and TechnipFMC's Involvement in Brazil between 2001 and 2014 | $ 55,000,000 |
| Panalpina's Involvement in Multiple Countries from 2002 to 2009 | $ 49,000,000 |
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."