The Department of Justice reports that an international consulting firm and its South African subsidiary will pay a criminal penalty of $122.9 million as part of a three-year deferred prosecution agreement resolving a DOJ investigation into a scheme to bribe government officials in South Africa between 2012 and 2016. In addition, both companies have agreed to enhance their compliance programs and to report to the government regarding remediation and implementation of those programs. Nicole Argentieri, who heads the DOJ’s Criminal Division, said this resolution “is evidence that our International Corporate Anti-Bribery initiative, which we announced in November 2023, is bearing fruit.”
According to the DOJ, the subsidiary paid bribes to then-officials at two South African state-owned and -controlled infrastructure companies to obtain lucrative consulting contracts that generated about $85 million in profits.
The DOJ notes that the subsidiary received credit for its cooperation with the department’s investigation, which included (1) collecting, reviewing, and producing voluminous records, including those located abroad, (2) promptly reporting the discovery of document-deletion efforts by the partner involved in the misconduct, (3) tracing complex internal accounting money flows and currency exchange information, and (4) engaging a third-party forensics consultant to analyze key electronic devices. Both companies also engaged in timely remedial measures, including (1) conducting additional anti-corruption training for employees in Africa, (2) enhancing due diligence processes for third-party partners, , and (3) carrying out an enhanced review process for all sole-source work that requires advance approval before the engagement can begin
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