The Department of Justice reports that it has entered into an 18-month non-prosecution agreement with a U.S. company, which will pay more than $55 million to resolve federal investigations related to violations of the Foreign Corrupt Practices Act. This amount includes a $26.4 million penalty as well as $29.2 million in disgorgement and prejudgment interest. Also under this NPA the company has agreed to continue to enhance its compliance program and report to the DOJ regarding its remediation and implementation of compliance measures.
According to a DOJ press release, the company admitted that between 2015 and 2020 it conspired to pay bribes to government officials to obtain and retain business with state-owned airlines in Nepal and South Africa. The company made nearly $24 million in profits as a result of this scheme.
The DOJ notes that it gave “significant weight” to the company’s self-reporting of some of the conduct at issue, even though this was not considered a voluntary self-disclosure for various reasons. The company also received credit for its “extensive and timely remedial measures,” which included conducting an enterprise-wide review of all existing high-risk third-party representatives, strengthening its anti-corruption compliance program, implementing a compliance risk assessment program that has enabled the company to proactively identify new areas of risk, implementing compliance auditing and periodic anti-corruption site reviews, and engaging in continuous testing, monitoring, and improvement of its compliance program.
For more information on the FCPA and how to ensure your company’s compliance, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.
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