With its $398 million enforcement action Wednesday, Total S.A. has landed fourth on our list of the Top 10 FCPA cases of all time.

Nine of the biggest cases involve non-U.S. companies, and three of the Top 10 are now French companies.

Dropping off the list is Panalpina of Switzerland.

This is the first change to the Top 10 list since December 2011.

_____________

*An individual, Jeffrey Tesler of the U.K., agreed to an FCPA-related forfeiture of $149 million in 2011.