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FX Fines Drive Record Year
The Department of Justice (DOJ) Antitrust Division imposed* a record USD2.853bn in criminal antitrust fines in fiscal year 2015, which concluded last week. The total in antitrust fines imposed in FY2015 (October 2014-September 2015) is more than twice the DOJ's previous record high and over three times greater than the fine total in FY2014.
![DOJ_2015_Graphic.jpg](https://jdsupra-html-images.s3-us-west-1.amazonaws.com/e1174708-2753-429d-811b-96e17e18f5dc-DOJ_2015_Graphic.jpg)
This FY's antitrust fine total is primarily the result of fines imposed in the DOJ's investigation of the foreign exchange (FX) market: fines imposed in the FX investigation account for 88% of the total criminal antitrust fines imposed by the DOJ this year. In May, a number of financial institutions pleaded guilty to, or settled charges relating to, manipulation of the FX market. These resolutions resulted in the imposition of USD2.52bn in fines, which included the Division’s largest individual fine of the fiscal year: USD925m levied against Citicorp. Fines imposed in the auto parts, capacitors, bearings, roll-on roll-off shipping, parking heaters, and e-commerce investigations (a total of USD333.6m) account for the balance of the DOJ's antitrust fine total for FY2015.
*This report reflects fines imposed by the DOJ – i.e., fines agreed to in plea agreements and other resolutions reached with the DOJ – as opposed to fines collected following sentencing of the respective defendants.