The ABCs of Corruption · Ledger D · Trade, Supply Chains and Oil

The Supply Chain

Bribes paid for foreign contracts, aluminum welded into fake pallets, tungsten relabeled in Taiwan, silicon from Xinjiang, cobalt dug by children, and two oil companies. Nine cases about the distance between the source and the shelf.

A supply chain is a sequence of handoffs, and each handoff is a place to put distance between a company and a fact. Siemens routed bribes through consultants. Perfectus welded Chinese extrusions into the shape of a finished product to change the tariff line, and Ceratizit is alleged to have changed a country of origin by shipping through Taiwan. Kraft Heinz's procurement staff kept supplier contracts that recorded savings nobody had earned. Google built the tools on both ends of the advertising market and the exchange between them.

In the cobalt case the distance itself was the defense, and it worked: five of the largest companies in the world bought the metal through enough intermediaries that the D.C. Circuit held they had not participated in the venture that produced it. The two oil cases are in this ledger because the harm sits at the end of their chain, in the Gulf and in the air.

D1Guilty plea

Siemens

Foreign bribery

$1,600,000,000to American and German authorities15 December 2008

Siemens paid bribes to officials around the world to win contracts in telecommunications, medical devices, power, transit and refineries. On 15 December 2008 Siemens AG and its subsidiaries in Argentina, Bangladesh and Venezuela pleaded guilty in federal court in Washington. The company paid $450,000,000 in criminal fines to the Justice Department and $350,000,000 in disgorgement to the SEC, which the department called the largest monetary sanction ever imposed under the Foreign Corrupt Practices Act. Munich prosecutors collected €395,000,000 the same day, on top of €201,000,000 in October 2007. The total passed $1,600,000,000, about half of it to each country. Siemens then announced a compliance overhaul.

The $1,600,000,000, in dollar equivalents

Munich prosecutor, 2008€395,000,000
Justice Department fines$450,000,000
SEC disgorgement$350,000,000
Munich prosecutor, 2007€201,000,000
“They called it brine. I call it a bribe with extra salt.”

Since

Eight former executives were indicted in December 2011. One of them, Eberhard Reichert, pleaded guilty on 15 March 2018.

D2Two liability rulings, on appeal

Alphabet

Google search and advertising technology

2 rulingsillegal monopoly, search and ad tech5 August 2024 and 17 April 2025

The Justice Department sued Google twice. The search case, filed on 20 October 2020, ended with Judge Amit Mehta finding on 5 August 2024 that Google illegally maintained its monopoly. His final judgment followed on 5 December 2025, and both sides have appealed. The advertising case, filed on 24 January 2023, concerned the machinery that sells ads across the web, where Google ran the tool publishers use to offer space, the tool advertisers use to buy it and the exchange between them. Judge Leonie Brinkema found Google liable on 17 April 2025. Her remedies order of 2 September 2026 declined to break off the exchange and imposed six years of conduct rules. Arkansas sued Google, YouTube and Alphabet on 30 September 2024, alleging that YouTube was deliberately designed to be addictive.

“They didn't win the market. They became the market.”

Since

Oral argument in the search appeal has not been scheduled. The Arkansas court refused to dismiss that case, and an appeal of the refusal was pending as of 31 August 2026.

D3Dismissed

Apple, Alphabet, Dell, Microsoft and Tesla

Doe v. Apple Inc., cobalt from the Democratic Republic of the Congo

$0paid by any of the five5 March 2024

Families of Congolese children killed or maimed in cobalt mines sued Apple, Alphabet, Dell, Microsoft and Tesla on 15 December 2019 under the federal trafficking statute, 18 U.S.C. § 1595. The complaint describes children, some as young as six, working in tunnels dug without structural support, with those under 14 earning an average of $0.81 a day. The district court dismissed the case in November 2021. On 5 March 2024 the D.C. Circuit affirmed in an opinion by Judge Neomi Rao: “Purchasing an unspecified amount of cobalt through the global supply chain is not ‘participation in a venture’ within the meaning of the TVPRA.” The court accepted that the families had standing to sue for damages and held that buying the metal was too far from the mines to count. Nobody paid anything and nobody admitted anything.

“The battery didn't die. The lawsuit did.”
D4Consent decree

BP

Deepwater Horizon

$20,800,000,000to the United States and five Gulf states4 April 2016

The Deepwater Horizon rig exploded on 20 April 2010 and killed 11 workers. The federal court in New Orleans later found that 3,190,000 barrels of oil, about 134,000,000 gallons, went into the Gulf of Mexico. BP's settlement with the United States and five Gulf states, announced on 5 October 2015 and entered by the court on 4 April 2016, was worth up to $20,800,000,000. The Justice Department called it the largest settlement with a single entity in the department's history, and called its Clean Water Act penalty the largest civil penalty in the history of environmental law. BP is still drilling in the Gulf.

The $20,800,000,000

Natural resource damages$8,100,000,000
Clean Water Act penalty$5,500,000,000
Economic claims of five Gulf states$4,900,000,000
Local governments, up to$1,000,000,000
Further natural resource damages, up to$700,000,000
Other federal claims$600,000,000
“The bill for what they did got paid. The bill for what they're still doing gets paid by the coastline.”
D5Allegation, pending

ExxonMobil

Climate science

63 to 83 percentof Exxon's own warming projections proved accurateSued 24 October 2019

Exxon's scientists modeled global warming for their employer from 1977 on. A 2023 study in Science by Geoffrey Supran, Stefan Rahmstorf and Naomi Oreskes went through 32 internal documents and 72 peer-reviewed papers and found that 63 to 83 percent of the company's own projections were accurate, predicting warming of about 0.20 °C per decade. Massachusetts Attorney General Maura Healey sued ExxonMobil on 24 October 2019 under the state consumer protection law, alleging a decades-long campaign to deceive consumers and investors about what the company knew. Exxon tried to move the case to federal court and then to have it thrown out as an attack on its speech. It lost both, the second before the Supreme Judicial Court on 24 May 2022. The case is pending in Suffolk Superior Court with no trial date. Exxon is still drilling.

“They knew the ice was melting. They just didn't want mine to.”
D6Import detention order

Hoshine Silicon Industry

Xinjiang forced labor

2 of 11ILO forced-labor indicators cited by Customs24 June 2021

Hoshine Silicon Industry makes metallurgical-grade silicon, the raw material that the polysilicon in solar panels and chips is refined from, a large share of it in Xinjiang. On 24 June 2021 U.S. Customs and Border Protection ordered ports to detain silica-based products made by Hoshine and its subsidiaries, and goods made from them anywhere in the world, citing two of the International Labour Organization's eleven indicators of forced labor: intimidation and threats, and restriction of movement. The Commerce Department put Hoshine on its Entity List the same day. The order reached far past one company, because importers of finished solar panels now had to trace their silicon back to the quartz.

“Clean energy. Dirty supply chain.”

Since

The order has since been absorbed into the Uyghur Forced Labor Prevention Act, which presumes goods from Xinjiang are made with forced labor until the importer proves otherwise.

D7SEC penalty

Kraft Heinz

Procurement accounting

$62,000,000civil penalty3 September 2021

From late 2015 through 2018 Kraft Heinz's procurement division booked discounts from suppliers that it had not yet earned and kept false and misleading supplier contracts to support them, across nearly 300 transactions. The cost savings looked real to investors. On 21 February 2019 the company wrote down the Kraft and Oscar Mayer brands by $15,400,000,000 and disclosed an SEC subpoena. It restated its accounts that June, correcting $208,000,000 in savings that had been recognized improperly. On 3 September 2021 it paid a civil penalty of $62,000,000. The former chief operating officer paid $300,000, and the former chief procurement officer paid $100,000 and accepted a five-year bar from serving as an officer or director.

Kraft Heinz, 2019 to 2023

Brand writedown$15,400,000,000
Shareholder settlement$450,000,000
Savings recognized improperly$208,000,000
SEC penalty$62,000,000
“They didn't just process the food. They processed the numbers too.”

Since

Shareholders settled their class action for $450,000,000 in 2023.

D8Settlement of allegations

Ceratizit USA

Tungsten carbide through Taiwan

$54,400,000agreed, no liability determined18 December 2025

Ceratizit USA of Charlotte, North Carolina agreed on 18 December 2025 to pay $54,400,000 to resolve a whistleblower's False Claims Act suit. The government alleged that from August 2020 through March 2024 the company brought Chinese tungsten carbide products in through Taiwan and declared them Taiwanese to avoid the Section 301 tariffs on Chinese goods, that from June 2015 it misclassified other products, and that it left off the country-of-origin marking the law requires. The whistleblower, Mark Stover, receives about $9,750,000. The Justice Department noted that the claims are allegations and that no liability was determined. Customs lawyers described it as the largest customs False Claims Act resolution to that date.

“Made in China. Labeled in Taiwan. Paid for by me.”

Since

Perfectus Aluminum passed it on 12 May 2026.

D9Jury conviction, consent judgment

Perfectus Aluminum

Pallets nobody bought

$549,594,030civil consent judgment12 May 2026

Aluminum extrusions from China carry antidumping and countervailing duties, and the countervailing rate alone was 374.15 percent. Finished goods were exempt. So between July 2011 and June 2014 Perfectus Aluminum and its affiliates imported extrusions spot-welded into the shape of pallets, declared them as finished merchandise and stacked them in Southern California warehouses. No customer ever bought one. A federal jury in Los Angeles convicted the companies on 23 August 2021 of conspiracy, wire fraud and passing false papers through a customhouse, and the court ordered $1,836,244,745 in restitution. The civil case, announced on 12 May 2026, alleges more than $3,000,000,000 in duties evaded on more than $880,000,000 of aluminum and ends in a consent judgment for $549,594,030, to be paid out of net sale proceeds.

Perfectus Aluminum

Duties evaded, as alleged$3,000,000,000
Criminal restitution ordered$1,836,244,745
Aluminum imported$880,000,000
Civil consent judgment$549,594,030
“They welded together a lie and called it a pallet.”

Since

The Ninth Circuit affirmed the convictions on 31 July 2024 and vacated part of the restitution order. Zhongtian Liu, founder of China Zhongwang Holdings, was indicted with the companies and is not a party to the settlement.

CaseOutcomeOn the recordDate
SiemensGuilty pleas in the United States, fines in Germany$1,600,000,00015 December 2008
AlphabetLiability found twice, appeals pendingNo fine5 August 2024
Apple, Alphabet, Dell, Microsoft and TeslaDismissal affirmed$05 March 2024
BPConsent decree$20,800,000,0004 April 2016
ExxonMobilAllegation, no trial dateNoneSued 24 October 2019
Hoshine Silicon IndustryImports detained at the borderNone24 June 2021
Kraft HeinzSEC civil penalty$62,000,0003 September 2021
Ceratizit USASettlement of allegations$54,400,00018 December 2025
Perfectus AluminumCriminal conviction, civil consent judgment$549,594,03012 May 2026

Customs fraud is the one corner of this ledger where enforcement has been getting larger. Customs lawyers described the Ceratizit resolution as the largest of its kind in December 2025, and the Perfectus judgment passed it five months later at ten times the size. Both began with insiders filing under the False Claims Act. The cases without an insider or a statute that fits have gone the other way. The cobalt plaintiffs lost on the pleadings. The Massachusetts case against Exxon is seven years old with no trial date. BP's $20,800,000,000 was the largest settlement the Justice Department had reached with a single company, and BP continues to operate in the same water.

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