Background

A Brazil-based investment company that owns and controls companies involved in multiple industries has agreed to pay a $256.5 million criminal penalty to the Department of Justice and enhance its compliance program after pleading guilty to violating the Foreign Corrupt Practices Act. In addition, a subsidiary of the company agreed to pay $26.9 million in disgorgement and pre-judgment interest and two owners agreed to each pay a $550,000 civil penalty to the Securities and Exchange Commission.

According to a DOJ press release, the company admitted that between 2005 and 2017 it paid more than $148 million in bribes to government officials in Brazil in exchange for obtaining hundreds of millions of dollars in financing and other benefits. As part of this scheme company executives used New York-based bank accounts to make corrupt payments, purchased and transferred a Manhattan apartment as a bribe, and met in the U.S. to discuss and further aspects of the scheme.

The DOJ notes that the company failed to voluntarily disclose the conduct and the nature, seriousness, and pervasiveness of the offense. However, the company also received partial credit for its remediation and cooperation with the department’s investigation.

Clients and potential clients requiring support related to the FCPA should contact Kristine Pirnia.

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