January 3, 2017

Top-5 Foreign Corrupt Practices Act (FCPA) Settlements for 2016

By the C|C Whistleblower Lawyer Team

Here is our look-back at the top-5 Foreign Corrupt Practices Act (FCPA) settlements for 2016. Click here for a chronological listing of all DOJ fraud recoveries for 2016.

5. Och-Ziff Capital Management Group LLC — The New York-based alternative investment and hedge fund manager, and its wholly-owned subsidiary OZ Africa Management GP LLC, agreed to pay a criminal penalty of more than $213 million to settle charges of violating the Foreign Corrupt Practices Act in connection with a widespread scheme involving the bribery of officials in the Democratic Republic of Congo and Libya. DOJ

4. JPMorgan Chase — The New York-based bank and its Hong Kong-based subsidiary JPMorgan Securities (Asia Pacific) Limited agreed to pay a combined total of roughly $265 million to resolve foreign bribery charges relating to JPMorgan’s so-called Sons and Daughters Program. Whistleblower Insider

3. Teva Pharmaceutical Industries Ltd. — The world’s largest manufacturer of generic pharmaceutical products, and its wholly-owned Russian subsidiary Teva LLC (Teva Russia) agreed to a total payout of $520 million in connection with schemes involving the bribery of government officials in Russia, Ukraine and Mexico in violation of the Foreign Corrupt Practices Act. DOJ

2. VimpelCom Limited — The Amsterdam-based telecommunications company and its wholly owned Uzbek subsidiary Unitel LLC agreed to pay roughly $795 million under settlements with the DOJ, SEC and the Public Prosecution Service of the Netherlands to settle charges of violating the anti-bribery provisions of the Foreign Corrupt Practices Act. Whistleblower Insider

1. Odebrecht S.A./Braskem S.A. — The Brazilian-based global construction conglomerate petrochemical company agreed to pay a combined total penalty of at least $3.5 billion to resolve charges with authorities in the United States, Brazil and Switzerland arising out of their schemes to pay hundreds of millions of dollars in bribes to government officials around the world in violation of the anti-bribery provisions of the Foreign Corrupt Practices Act. DOJ

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