Corruption & Bribery
Documented corruption, bribery, or fraud in business operations or government dealings — FCPA violations, UK Bribery Act enforcement, kickback schemes, bid-rigging with government agencies, and systematic deception of regulators. Includes both direct bribery and facilitation payments through intermediaries. Distinct from financial_misconduct (which covers consumer-facing fraud) and political_influence (which covers legal lobbying and campaign contributions).
Excluded Companies (46 total)
Showing 25 of 46 companies excluded under this screen.
| Ticker | Company | Reason |
|---|---|---|
| CAH | Cardinal Health | Cardinal Health has been subject to multiple enforcement actions for corruption and fraud in its business operations. In February 2020, the SEC charged Cardinal Health with violating the Foreign Corrupt Practices Act (FCPA), resulting in an $8.8 million settlement. The SEC order found that employees at its former Chinese subsidiary, Cardinal Health China, directed improper payments to government-employed healthcare professionals to induce the purchase of medical devices, circumventing the company's internal accounting controls. This pattern of misconduct extends to domestic operations. In January 2022, Cardinal Health agreed to pay more than $13 million to resolve allegations it violated the Controlled Substances Act by failing to report suspicious orders of opioids to the Drug Enforcement Administration. This followed a separate $44 million settlement in 2016 for alleged record-keeping violations of the same Act. The Federal Trade Commission also reached a settlement with Cardinal Health in 2015 for anticompetitive conduct. ViolationTracker documents a total of $213.7 million in penalties across 43 environmental, consumer protection, and other regulatory enforcement records for the company. |
| KO | Coca-Cola Company (The) | The Coca-Cola Company has faced multiple documented instances of corruption and bribery within its global operations and bottling network. In April 2022, a former Coca-Cola Enterprises manager in the UK pleaded guilty to accepting more than £1.5 million in bribes from suppliers in exchange for helping them win contracts. This case, prosecuted by the UK's Crown Prosecution Service, involved guilty pleas from supplier companies Tritec Systems and Electron Systems for corruption and failure to prevent bribery. Separately, an investigation into the company's Uzbekistan bottling operations alleged complicity in a government seizure of a lucrative venture from U.S. citizens in 2021. The Coca-Cola Company was reportedly aware of potential legal challenges when the Uzbek government forcibly took control of the business. These incidents follow a pattern of corruption allegations across the Coca-Cola system, which a 2011 investigative report described as "ripe with immorality and corruption." While the company maintains a public Anti-Bribery Policy and Code of Business Conduct, these enforcement actions demonstrate recurring failures to prevent corruption within its extended enterprise. |
| 601668.SS | China State Construction Engineering Corporation Limited | China State Construction Engineering Corporation Limited (CSCEC) has been excluded due to documented corruption and bribery in its international business operations. The company has faced multiple enforcement actions and allegations related to corrupt practices in its overseas projects. The Norwegian Government Pension Fund Global (NBIM) excluded CSCEC in 2024 based on an assessment of unacceptable corruption risk. The fund's Council on Ethics cited specific concerns regarding the company's operations in Africa, where corruption exposure is a known business risk. Academic research has identified a correlation between firms operating in Africa and higher corruption exposure, with some studies suggesting such exposure can be linked to valuation gains, indicating a potential competitive advantage derived from operating in corrupt environments. While CSCEC is a state-owned enterprise subject to China's domestic anti-corruption campaigns, its international operations, particularly in high-risk regions, have drawn scrutiny from global institutional investors focused on governance and integrity risks. |
| TV | Grupo Televisa | Grupo Televisa has faced significant allegations of corruption and bribery in its business dealings. In 2022, the U.S. Securities and Exchange Commission (SEC) charged the company with violating the Foreign Corrupt Practices Act (FCPA). The SEC's order (Administrative Proceeding File No. 3-20949) documented that Televisa, through its subsidiary, paid approximately $4.1 million in bribes to a Mexican government official to obtain a favorable judicial decision in a civil lawsuit. The company agreed to pay a $3 million civil penalty to settle the charges. Separately, Televisa has been accused of using its media influence as a tool for political and business advantage. Reports from media watchdogs and investigative journalists allege the company operated a secret network to spread disinformation and fabricate false allegations against political rivals and business competitors. This pattern of leveraging its broadcast platforms for corrupt purposes extends beyond the FCPA violation, indicating systemic governance failures. |
| EXC | Exelon | Exelon and its subsidiary Commonwealth Edison paid $46.2 million to settle SEC fraud charges in September 2023 for concealing a multi-year political corruption scheme from investors. The SEC complaint detailed that ComEd corruptly influenced former Illinois House Speaker Michael Madigan by directing over $1.3 million in payments and benefits to his associates, in exchange for favorable legislation affecting the utility’s operations and rate structure. This settlement was part of broader legal repercussions from the scheme. In a related class action, Exelon paid $173 million to investors in May 2023 for allegations it concealed the bribery. Overall, ViolationTracker documents Exelon’s penalty history includes $200 million for kickbacks and bribery across one case, alongside dozens of other environmental and consumer protection violations. The SEC’s action against a former Exelon executive signals the enforcement extended to individual accountability for the internal control failures that allowed the corruption. |
| BOL.PA | Bolloré SE | Bolloré SE entered into a judicial public interest agreement (CJIP) with the French National Financial Prosecutor's Office in July 2021, agreeing to pay a €12 million fine and implement a compliance program to resolve allegations of corruption. The investigation centered on the group's historic logistics operations in Africa, specifically concerning the bribery of foreign public officials. While the CJIP did not require an admission of guilt, it was predicated on the recognition of facts related to these corruption allegations. In March 2025, a coalition of NGOs filed a criminal complaint in France accusing the Bolloré group of being at the heart of a "system of corruption" in Africa. The complaint alleges the company used corrupt practices to secure port concessions and other logistics contracts. This legal action, led by the French NGO Sherpa, extends the scrutiny beyond the settled case, framing the conduct as a repeated pattern to gain business advantages on the continent. |
| FNF | Fidelity National Financial Inc | Fidelity National Financial has a documented history of corruption and bribery violations in its core title insurance operations. In 2011, the company paid $4.5 million to settle federal charges that its subsidiaries, Fidelity National Title Insurance Co. and Chicago Title Insurance Co., participated in a nationwide kickback scheme. The violations, documented in ViolationTracker, involved illegal payments and rebates designed to steer real estate transactions. Separately, the company has faced legal action alleging violations of the Foreign Corrupt Practices Act (FCPA) in its business dealings in China. A breach of contract claim filed by a former executive also alleged the company violated anti-bribery laws in its interactions with a bank customer there. While Fidelity National Financial refutes claims of disclosure law violations, it continues to face numerous lawsuits related to a mortgage fraud scheme in San Diego, indicating ongoing legal risk from its business conduct. |
| LVS | Las Vegas Sands Corp. | Las Vegas Sands Corp. has been subject to multiple enforcement actions by U.S. authorities for violations of the Foreign Corrupt Practices Act (FCPA). In 2023, the company agreed to pay a $9 million penalty to settle SEC charges that it failed to devise and maintain adequate internal accounting controls related to its operations in Asia from 2006 through at least 2011. This followed a 2017 non-prosecution agreement with the Department of Justice, under which Sands paid a $6.96 million criminal penalty for FCPA violations. ViolationTracker documents total penalties of over $47 million for the company, stemming from anti-money-laundering deficiencies and FCPA violations. The company itself disclosed in 2013 that it had likely violated U.S. anti-bribery law. These repeated settlements and deficiencies point to a sustained pattern of internal control failures and violations of anti-corruption statutes in its international casino operations. |
| BDRBF | Bombardier, Inc. Class B | Bombardier has been the subject of multiple international corruption investigations related to its aircraft and railway sales. In 2017, Sweden’s National Anti-Corruption Unit charged a Bombardier employee based in Stockholm with aggravated bribery. In 2020, the UK Serious Fraud Office (SFO) opened an investigation into suspected bribery concerning contracts with Garuda Indonesia. The U.S. Department of Justice also launched two Foreign Corrupt Practices Act investigations into the company in 2020, one related to a railway equipment deal in Azerbaijan and another concerning an aviation deal in Indonesia. While the DOJ closed these two probes without charges in May 2025, the company continues to cooperate with a third, separate investigation. In 2024, Norway’s Council on Ethics noted that Bombardier had provided limited documentation to demonstrate the effectiveness of its anti-corruption controls during an extended observation period. |
| ZTCOF | ZTE Corp | ZTE Corp has a documented history of engaging in corrupt business practices and violating international sanctions. In 2017, the company pleaded guilty and paid nearly $900 million in U.S. criminal and civil penalties for illegally shipping telecommunications equipment to Iran and North Korea, in violation of U.S. sanctions. This settlement totaled $1.2 billion. As of late 2025, the company is again facing U.S. regulatory scrutiny, with reports indicating it may pay over $1 billion to resolve years-old allegations of foreign bribery. These allegations are not isolated; ZTE was also central to the Philippine National Broadband Network controversy, a major corruption scandal involving bribery allegations for a government contract. This pattern of misconduct, spanning sanctions evasion and bribery allegations across multiple countries, demonstrates systemic failures in governance and legal compliance. |
| WYNN | Wynn Resorts, Limited | Wynn Resorts, Limited has been the subject of multiple federal investigations concerning potential violations of the Foreign Corrupt Practices Act (FCPA). The U.S. Securities and Exchange Commission (SEC) has investigated donations made by the company, with one inquiry examining a $135 million charitable contribution that may have implicated FCPA issues. In September 2024, the company's Las Vegas casino subsidiary, Wynn Las Vegas, agreed to forfeit $130,131,645 to settle a federal investigation. The U.S. Department of Justice found the company had illegally conspired with and later compensated a former customer who was convicted of running an illegal sportsbook operation from its suites, constituting a conspiracy to violate anti-money laundering reporting requirements. This settlement represents one of the largest corporate forfeitures in a gaming-related case. |
| ADANIGREEN | Adani Green Energy Limited | Adani Green Energy Limited is named in a U.S. Securities and Exchange Commission (SEC) civil complaint and a related Department of Justice indictment alleging a bribery scheme to secure multi-billion-dollar energy projects. The November 2024 SEC filing details a scheme to funnel bribes to foreign officials, explicitly naming projects intended for Adani Green Energy Limited. While the company has clarified it is not a direct party to the proceedings and no charges have been brought against the corporate entity itself, the allegations specifically name its leadership, including Chairman Gautam Adani and senior executives, as participants. The severity of the allegations, involving high-value renewable energy contracts, prompted the world’s largest sovereign wealth fund to exclude Adani Green from its portfolio in early 2026, citing unacceptable corruption risk. |
| JBSAY | JBS SA | JBS SA, the world's largest meat producer, has been at the center of major corruption scandals involving its controlling shareholder, J&F Investimentos. In 2017, J&F agreed to a record $3.2 billion leniency fine with Brazilian authorities for its role in widespread corruption, admitting to bribing hundreds of politicians. The holding company's founders, Joesley and Wesley Batista, provided evidence that led to the impeachment of a president. ViolationTracker documents an additional $541 million in penalties for JBS, including for violations of the Foreign Corrupt Practices Act. In December 2023, Brazil's Supreme Court suspended the $2 billion remaining portion of the original fine, a decision that drew significant public criticism. The company's history of corrupt dealings with government officials has been a persistent feature of its operations. |
| MMC | MARSH & MCLENNAN COMPANIES INC | Marsh & McLennan orchestrated a systematic bid-rigging and price-fixing scheme in the commercial insurance brokerage industry. The company designated which insurer's bid would win particular accounts and instructed competing insurers to submit inflated, intentionally uncompetitive bids, creating a false appearance of competitive bidding. New York Attorney General Eliot Spitzer charged eight former MMC executives with felonies. In January 2005, MMC agreed to pay $850 million in restitution to policyholders who purchased insurance between 2001 and 2004. The company subsequently settled with nine additional state attorneys general for $7 million and paid $24 million to Connecticut alone. The scheme affected commercial insurance customers nationwide who paid artificially inflated premiums. |
| TS | Tenaris S.A. | Tenaris S.A.'s Brazilian subsidiary Confab Industrial paid at least $10.4 million in bribes between 2008 and 2013 to a senior procurement manager at state-owned Petrobras, securing over $1 billion in steel pipe contracts. The SEC charged Tenaris with violating the FCPA's anti-bribery, books-and-records, and internal accounting controls provisions in June 2022. Tenaris agreed to pay $78.1 million comprising $42.8 million in disgorgement, $10.3 million in prejudgment interest, and a $25 million civil penalty. This was Tenaris's second FCPA enforcement action; in 2011 the company entered a non-prosecution agreement with the DOJ and a deferred prosecution agreement with the SEC over bribes paid to a state-owned entity in Uzbekistan, establishing a pattern of recidivist foreign corruption. |
| GE | General Electric Company | General Electric has paid multiple significant penalties to resolve charges of financial misconduct and corruption. In December 2020, the company agreed to pay a $200 million penalty to settle Securities and Exchange Commission charges for disclosure failures that misled investors about its power and insurance businesses. This followed a separate $1.5 billion settlement in 2019 with the Department of Justice to resolve allegations that its WMC mortgage subsidiary misrepresented the quality of its loans and the strength of its internal fraud controls. The SEC has also previously charged GE and two subsidiaries with violating the Foreign Corrupt Practices Act. According to ViolationTracker, GE’s top offenses by penalty value include toxic securities abuses and accounting fraud. |
| DAL | Delta Air Lines, Inc. | Delta Air Lines agreed to pay $8.1 million in July 2025 to settle Department of Justice allegations that it violated the False Claims Act by exceeding executive compensation limits it agreed to as a condition of receiving federal CARES Act payroll support during the pandemic. Between March 2020 and April 2023, Delta awarded compensation to corporate officers and employees beyond program limits and then inaccurately certified compliance in quarterly reports submitted to the Department of the Treasury. Separately, the New York Attorney General indicted five individuals in connection with bribery and money laundering schemes at JFK Airport spanning 2018 to 2023, in which a high-level Delta employee accepted approximately $375,000 in bribes to steer cargo contracts. |
| IRM | IRON MOUNTAIN INC | Iron Mountain paid $44.5M (December 2014) to settle False Claims Act allegations that it systematically overcharged federal agencies for record-storage services under GSA contracts from 2001-2014. The company failed to provide GSA with accurate commercial pricing during negotiations, did not offer required lower government rates, and charged for storage that failed to meet National Archives standards. A whistleblower lawsuit filed by former employee Brent Stanley and Patrick McKillop exposed the fraud; they received $8M+ from the recovery. Iron Mountain also paid $1.57M to California and San Bernardino/Santa Clara counties for parallel state false claims. |
| TTWO | TAKE TWO INTERACTIVE SOFTWARE INC | Take-Two Interactive engaged in systematic revenue fraud from 2000-2001, improperly recognizing ~$60M through approximately 180 "parking" transactions. The company shipped hundreds of thousands of video games to distributors with no obligation to pay, recorded them as sales, then accepted returns in later periods. A key example: VP Robert Blau arranged a 230,000-unit shipment to Capitol Distributing on the last day of fiscal 2000, recording $5.4M in fake revenue, then disguised the return through a Capitol affiliate. The fraud inflated after-tax FY2000 earnings by $20M. SEC penalties totaled ~$14M across Take-Two ($7.5M) and four executives. |
| ACEL | ACCEL ENTERTAINMENT INC CLASS A | Propublica notes "interviews with current and former Accel employees who asked to remain anonymous, reveal that Rubenstein and his company also took advantage of connections at the Illinois Gaming Board. They did so using an unusual degree of access to a key board attorney during video gambling’s earliest days, when regulations were being drafted and the competition to lock up gambling locations was at its fiercest. In addition, the company obtained internal gaming board documents about its competitors and benefited from board decisions that made it more difficult for other operators to gain a foothold in Illinois’ video gambling market." |
| ALB | Albemarle Corporation | Albemarle Corporation paid ~$218.5M in combined DOJ/SEC FCPA settlements (September 2023) for systematic bribery through third-party sales agents and subsidiary employees in Vietnam, Indonesia, and India between 2009-2017. In Vietnam, agents bribed officials at two state-owned oil refineries. In Indonesia, intermediaries paid bribes to win business with the state oil company despite explicit knowledge of the corruption. In India, agents bribed officials to prevent Albemarle from being blacklisted. Total penalties: $99M criminal fine, ~$98M forfeiture, plus $103.6M SEC disgorgement and interest. Albemarle profited ~$98.5M from the scheme. |
| AON | AON PLC | Aon Corporation paid $16.3M in combined DOJ/SEC FCPA penalties (December 2011) for improper payments across seven countries between 1983-2007. Subsidiaries made over $3.6M in bribes to secure or retain insurance business in Costa Rica, Egypt, Vietnam, Indonesia, UAE, Myanmar, and Bangladesh. Payments fell into two categories: training/travel/entertainment for government-owned client employees, and direct payments to third-party facilitators. SEC disgorgement totaled $14.5M; DOJ criminal fine was $1.76M. The breadth of jurisdictions and 24-year timespan reflect deeply embedded corrupt practices across the global insurance brokerage. |
| IT | GARTNER INC | Gartner Inc. paid $2.5M to settle SEC charges (May 2023) for FCPA anti-bribery, books-and-records, and internal controls violations in South Africa. From December 2014 through August 2015, Gartner entered a corrupt arrangement with a private South African company tied to government officials, knowing payments would be used to bribe officials to influence consulting contract awards. Gartner's own internal risk assessments had flagged bribery red flags in third-party relationships, but the company lacked adequate screening, onboarding, and monitoring procedures for vendors. Penalties: $856,764 disgorgement plus $1.6M civil penalty. |
| F | Ford Motor Company | Ford Motor Company paid $365M in March 2024 to settle customs fraud charges for systematically evading import duties on Transit Connect cargo vans manufactured in Turkey. From 2009 onward, Ford outfitted the vans with sham passenger seats designed to be removed immediately after clearing customs, misclassifying them as "passenger vehicles" (2.5% tariff) instead of light-duty cargo vehicles (25% tariff). Just over half the settlement ($183.5M) was restitution for owed duties. The scheme was exposed by a whistleblower. A separate $12.8M FCPA-related settlement for foreign bribery violations is recorded on ViolationTracker. |
| HSIC | HENRY SCHEIN INC | Henry Schein Inc., the world's largest distributor of healthcare products to office-based practitioners, has accumulated $41M+ in penalties since 2000 per ViolationTracker. Enforcement actions include a $35M antitrust settlement (2020) for conspiring with Benco and Patterson to restrain competition and inflate dental product prices, a $500K controlled substances settlement for improper opioid distribution (2012-2018), and FTC action for deceptive encryption claims in its Dentrix dental software. The pattern reflects systemic compliance failures across antitrust, controlled substances, and consumer protection. |
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The Naughty List
A digest of changes to our exclusion list — new additions, removals, and the evidence behind them. We review the list continuously as new evidence surfaces.