61. Siemens 2008 ($1,351 million)
Siemens, the world’s largest electronics company, paid the highest-ever foreign bribery penalty in 2008, split between US and German authorities. In total, it agreed to pay US$1.35 billion – a US$450 million criminal fine to the DOJ, a further US$350 million disgorgement to the SEC after admitting FCPA books and records failures, and US$550 million in disgorgement on top of a US$348,000 criminal fine to Germany.
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