ETHIC Intelligence hosts its third annual international conference
on corruption prevention Standards and Guidelines

OECD Conference Centre, Paris - Monday, September 10, 2018

ETHIC Intelligence is very pleased to host its third annual international conference on Standards and Guidelines in corruption prevention on September 10, 2018 at the OECD Conference Centre in Paris. Click below to view photos and videos from last year’s event where experts from business, civil society and government exchanged and debated issues related to the fight against corruption.

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legislation – noteworthy case law

The ETHIC Intelligence team regularly monitors transnational corruption case law and other relevant court cases. This section includes significant cases whose results could have an impact on the way companies conduct business at home and abroad.

Latest cases in 2018, by date and by company:


February 9, 2018 – AIRBUS

Airbus SE has agreed to pay an 81 million euro fine to end a five-year bribery investigation by German prosecutors in connection with Eurofighter jets the defense company sold to Austria in 2003. The Munich Public Prosecutor found former Airbus space and defense executives were guilty of “negligent breach of supervisory duties” by failing to implement internal controls. The probe failed to find any evidence of bribes.


January 14, 2018 – TEVA Pharmaceuticals

The taxation and economic section of the Israeli State Attorney’s Office, with the approval of State Attorney Shai Nitzan, signed a conditional arrangement for an end to proceedings yesterday with Teva Pharmaceutical Industries Ltd.  under the Securities Law. The settlement provides that Teva will admit involvement in a bribery affair in Russia and Ukraine, and will pay a NIS 75  (USD 22M) million penalty. An investigation carried out in the US found that Teva had made corrupt payments to public officials in Russia and Ukraine, and had also made inappropriate payments in Mexico, as a result of which it garnered profits amounting to at least $220 million. Some of the payments, made by overseas subsidiaries wholly owned by Teva, were not described for what they really were in the companies’ financial statements, but were presented as legitimate expenses, and were consolidated as such in the financial statements of Teva.


December 22, 2017 – Keppel Offshore & Marine Ltd.

Keppel Offshore & Marine Ltd. (KOM), a Singapore-based company that operates shipyards and repairs and upgrades shipping vessels, and its wholly owned U.S. subsidiary, Keppel Offshore & Marine USA Inc. (KOM USA), have agreed to pay a combined total penalty of more than USD422 million to resolve charges with authorities in the United States, Brazil and Singapore arising out of a decade-long scheme to pay millions of dollars in bribes to officials in Brazil.



December 1 , 2017 – SBM Offshore


SBM Offshore NV (SBMO.AS), a Netherlands-based maker of offshore oil drilling equipment, and its U.S subsidiary, SBM Offshore USA Inc, have agreed to settle criminal charges of bribing officials in five countries and pay a US$238 million penalty according to the US Department of Justice. The companies have agreed to settle charges related to schemes lasting more than a decade involving bribery of foreign officials in Brazil, Angola, Equatorial Guinea, Kazakhstan and Iraq.



September 29, 2017 – ALERE

Alere Inc has agreed to pay more than $13 million to resolve charges the diagnostic testing firm committed accounting fraud and made improper payments to foreign officials, the U.S. Securities and Exchange Commission has said. The settlement with Alere resolved an investigation that began in 2015 before Abbott Laboratories agreed to buy the Waltham, Massachusetts-based company in a $5.3 billion deal expected to close later in 2017. Alere, which manufactures and sells diagnostic tests, did not admit wrongdoing as part of the settlement. 



September 25, 2017 – former Alstom Executive Frédéric Pierucci

A former executive of French power and transportation company Alstom was sentenced in the U.S. on September 25 2 ½ years in prison for bribing Indonesian officials — a scheme that was part of a worldwide bribery scandal resulting in a record $772 million fine against the company. Frederic Pierucci, a 49-year-old French citizen, also was fined $20,000 at his sentencing in federal court in New Haven, Connecticut. He pleaded guilty in 2013 to violating and conspiring to violate the FCPA. Pierucci was vice president of global sales for an Alstom subsidiary in Windsor, Connecticut, that has since been acquired by General Electric Co. He, several other Alstom officials and an Alstom business partner were indicted on U.S. charges that they bribed several Indonesian government officials, including a member of Parliament, offering hundreds of thousands of dollars between 2002 and 2009 to secure a $118 million contract for a power project in Tarahan to provide electricity to citizens.

September 21, 2017 – Telia Company AB + Uzbek subsidiary Coscom

Stockholm-based Telia Company AB, an international telecommunications company that was formerly an issuer of publicly traded securities in the U.S., and its Uzbek subsidiary, Coscom LLC, entered into a global foreign bribery resolution with the US Department of Justice and agreed to pay a combined total penalty of more than $965 million to resolve charges arising out of a scheme to pay bribes in Uzbekistan. Telia entered into a deferred prosecution agreement in connection with a criminal information filed in the Southern District of New York charging the company with conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA).  In addition, Coscom, an Uzbek subsidiary,  pleaded guilty and was sentenced on a one-count criminal information charging the company with conspiracy to violate the anti-bribery provisions of the FCPA.  Pursuant to its agreement with the Department, Telia agreed to pay a total criminal penalty of $274,603,972 to the U.S., including a $500,000 criminal fine and $40 million in criminal forfeiture that Telia agreed to pay on behalf of Coscom.  Telia also agreed to implement rigorous internal controls and cooperate fully with the Department’s ongoing investigation, including its investigation of individuals. The criminal portion of the fine will be split between the U.S. and Dutch authorities. The total penalty amount also includes a $457 million disgorgement to the SEC.


July 27, 2017 – Halliburton

The Securities & Exchange Commission charged Halliburton Company with violating the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act (FCPA) while selecting and making payments to a local company in Angola in the course of winning lucrative oilfield services contracts. Halliburton, which profited by approximately US$14 million from the deals, has agreed to pay more than US$29.2 million to settle the SEC’s case. The company also agreed to obtain an independent compliance consultant to oversee its anti-corruption policies and procedures in Africa. Halliburton’s former vice president Jeannot Lorenz has agreed to pay a US$75,000 penalty for causing the company’s violations, circumventing internal accounting controls, and falsifying books and records. 

July 7, 2017 – ADDAX

Addax Petroleum has agreed to pay 31 million Swiss francs (USD32 million) to settle charges of suspected bribery of foreign officials with the Geneva prosecutor’s office.  A four-month investigation found the payments were not sufficiently documented and doubts remained on their legality, but no criminal intent was established, the Geneva prosecutor’s office said in a statement. It added that Addax acknowledged possible organisational shortcomings and had taken measures to improve internal anti-corruption procedures.


May 31, 2017 – JBS

The controlling shareholder of the world’s largest meat-packing company, JBS, has agreed to pay a record 10.3bn real (US$3.2bn) fine to Brazilian authorities for its role in Brazil’s corruption scandals. J&F Investimentos will pay under a leniency deal in two corruption investigations. 

May 31, 2017 – Samuel Mebiame

A dual citizen of Gabon and France was sentenced to 24 months in prison for his role in a conspiracy to pay bribes to senior government officials across Africa, in violation of the Foreign Corrupt Practices Act (FCPA). According to admissions made at his plea hearing, Samuel Mebiame formed a conspiracy to provide improper benefits to government officials in multiple countries in Africa. Mebiame admitted that the improper benefits he provided were intended to influence the performance of official governmental duties, and that he took steps to further the conspiracy while physically in New York. Based on court documents, Mebiame worked as a “fixer” on behalf of a joint venture company owned by New-York-based hedge fund Och-Ziff Capital Management Group LLC (Och-Ziff) and its business partner, a Turks and Caicos Islands-registered corporate entity controlled by a co-conspirator. 

April 24, 2017 – Former Magyar Telekom executives

The Securities and Exchange Commission today announced that two former executives at Hungarian-based telecommunications company Magyar Telekom have agreed to pay financial penalties and accept officer-and-director bars to settle a previously-filed SEC case alleging they violated the Foreign Corrupt Practices Act (FCPA). Magyar Telekom paid a $95 million penalty in December 2011 to settle parallel civil and criminal charges that the company bribed officials in Macedonia and Montenegro to win business and shut out competition in the telecommunications industry.  The SEC’s complaint also charged the company’s former CEO Elek Straub and former chief strategy officer Andras Balogh with orchestrating the use of sham contracts to funnel millions of dollars in corrupt payments.  The two executives were set to stand trial this month. Straub has agreed to pay a $250,000 penalty and Balogh has agreed to pay a $150,000 penalty.  Both executives agreed to a five-year bar from serving as an officer or director of any SEC-registered public company.  The settlements are subject to court approval.

March 30, 2017 – Douglas Ray, President & owner of Global Aviation Services

Douglas Ray, the President and owner of Global Aviation Services, has been sentenced to 18 months in prison, 3 years of supervised release and USD 590,000 in restitution for his role in a scheme to bribe Mexican public officials in order to secure aircraft maintenance and repairs contracts with government-owned and controlled entities. Five other individuals have also pleaded guilty. 

January 19, 2017 – Las Vegas Sands Corp

Las Vegas Sands Corp agreed to pay a US$6.96 million penalty to end a U.S. Department of Justice probe into whether it violated a federal anti-bribery law by making payments to a consultant to help it do business in China and Macau. The casino operator also entered a non-prosecution agreement, in which it admitted that executives knowingly failed to set up accounting controls to ensure that the payments were legitimate, and were properly recorded in its books and records.  

January 18, 2017 – ORTHOFIX

The US Securities and Exchange Commission has announced that Texas-based medical device company Orthofix International has agreed to admit wrongdoing and pay more than US$14 million to settle charges that it improperly booked revenue in certain instances and made improper payments to doctors at government-owned hospitals in Brazil in order to increase sales. Orthofix has agreed to pay a US$8.25 million penalty to resolve the accounting violations and more than $6 million in disgorgement and penalties to settle the FCPA charges. The company agreed to retain an independent compliance consultant for one year to review and test its FCPA compliance program. Jeff Hammel, a former accounting executive in Orthofix’s largest business segment, agreed to pay a US$20,000 penalty and former sales executives Kenneth Mack and Bryan McMillan agreed to pay penalties of $40,000 and $25,000 respectively. Orthofox’s former corporate CFO, Brian McCollom, agreed to pay a $35,000 penalty and reimburse the company $40,885 for bonuses he received during the period when the company committed accounting violations. 

January 17, 2017 – Kendrick Wallace, former Chief Legal Officer, YARA International

A Norwegian appeals court has sentenced the former chief legal officer of fertilizer-maker Yara International, Kendrick Wallace, to seven years in prison in a bribery case. The Borgarting Appeal Court, a regional court in southeast Norway, upheld 71-year-old Wallace’s guilt in December. Wallace, an American, had originally been convicted to 2-1/2 years in prison by a lower court. Prosecutors had originally accused four Yara executives of paying bribes to officials in India and Libya, but only Wallace was convicted in the appeals case, while the three others were acquitted.

January 16, 2017 – Rolls Royce Plc

British engineering group Rolls-Royce Plc has reached settlements with authorities in Britain, the United States and Brazil relating to bribery and corruption involving intermediaries. These settlements will result in a series of payments totaling 671 million pounds (US$809 million). Under the terms of the agreements with the U.S. Department of Justice, Brazil’s Ministerio Publico Federal (MPF) Rolls has agreed to make payments to the DOJ totaling nearly US$170 million and to the MPF totaling US$25.58 million. Under the terms of a deferred prosecution agreement with Britain’s Serious Fraud Office the company said it will pay $497.25 million plus interest under a schedule lasting up to five years, plus a payment in respect of the SFO’s costs. The proposed agreement with the Serious Fraud Office is still subject to court approval.

January 9, 2017 – Mondelez International

Mondelez International has agreed to pay the US Securities and Exchange Commission (SEC) US$13 million in civil penalties without admitting or denying charges that its subsidiary Cadbury India (now Mondelez India Foods) paid a consultant who was suspected to have bribed government officials and possibily top state politicians to obtain licenses and approvals for a chocolate factory in Baddi, Himachal Pradesh. The agreement settles the charges related to internal controls and books-and-records provisions of the FCPA.



December 29, 2016 – General Cable

General Cable, a Kentucky-based manufacturer and distributor of cable and wire, entered into a non-prosecution agreement and agreed to pay a US$20 million penalty, reflecting a 50 percent reduction off the bottom of the U.S. Sentencing Guidelines fine range, to resolve the government’s investigation into improper payments to government officials in Angola, Bangladesh, China, Indonesia and Thailand to gain business in violation of the FCPA. 



December 22, 2016 – TEVA Pharmaceuticals

The SEC has announced that Teva Pharmaceutical Industries Limited has agreed to pay more than US$519 million to settle parallel civil and criminal charges that it violated the Foreign Corrupt Practices Act by paying bribes to foreign government offcials in Russia, Ukraine and Mexico. 



December 21, 2016 – Odebrecht S.A. and Braskem

Odebrecht S.A., a global construction conglomerate based in Brazil, and Braskem S.A., a Brazilian petrochemical company, have pleaded guilty and agreed to pay a combined total of at least US$3.5 billion to resolve charges with authorities in the United States, Brazil and Switzerland arising out of their schemes to pay hundreds of millions of dollars in bribes to government officials around the world. In related proceedings, Braskem also settled with the U.S. Securities and Exchange Commission (SEC), the Ministerio Publico Federal in Brazil and the Office of the Attorney General in Switzerland. Under the terms of its resolution with the SEC, Braskem agreed to a total of US$325 million in disgorgement of profits.

November 17, 2016 – JPMorgan Chase

The SEC has announced that JPMorgan Chase & Co. has agreed to pay more than US$130 million to settle SEC charges that it won business from clients and corruptly influenced government officials in the Asia-Pacific region by giving jobs and internships to their relatives and friends in violation of the Foreign Corrupt Practices Act (FCPA). In addition, JPMorgan Securities (Asia PAcific) Limited (JPMorgan APAC), a Hong Kong-based subsidiary of multinational bank JPMorgan Chase & Co. (JPMC) agreed to pay the Department of Justice a US$72 million penalty for its role in the scheme to corruptly gain advantages in winning banking deals by awarding prestigious jobs to relatives and friends of Chinese government officials. The Federal Reserve Board, for its part, ordered JPMorgan Chase & Co. to pay a US$61.9 million civil money penalty for unsafe and unsound practices related to the firm’s practice of hiring individuals referred by foreign officials.

October 24, 2016 – Embraer

Brazilian aircraft manufacturer Embraer S.A. has entered into a resolution to resolve criminal charges and agreed to pay a penalty of more than US$107 million in connection with schemes involving the bribery of government officials in the Dominican Republic,  Saudi Arabia and Mozambique, and to pay millions more in falsely recorded payments in India via sham agency agreements. In addition, Embraer has entered into a three-year deferred prosecution agreement. Embraer will also pay more than US$98 million to the SEC in disgorgement and interest. 

October 3, 2016 – GlaxoSmithKline

GlaxoSmithKline PLC has agreed to pay US$20 million to the US Securities and Exchange Commission to settle allegations that a Chinese subsidiary of the pharmaceutical company bribed foreign officials to increase products sales. The subsidiary and another joint venture provided the officials with gifts, travel and shopping excursions from at least 2010 to June 2013. GSK failed to maintain sufficient internal accounting controls and an anti-corruption compliance program, which led to instances of similar improper conduct in other countries according to the SEC. 

September 30, 2016 – Och-Ziff

The Securities and Exchange Commission has announced that Och-Ziff Capital Management Group agreed to pay nearly $200 million to the SEC to settle civil charges of violating the Foreign Corrupt Practices Act (FCPA). Och-Ziff CEO Daniel S. Och agreed to pay nearly $2.2 million to settle SEC charges that he caused certain violations along with CFO Joel M. Frank, who also agreed to settle the charges. The SEC detected the misconduct while proactively scrutinizing the way that financial services firms were obtaining investments from sovereign wealth funds overseas.  The SEC’s subsequent investigation of Och-Ziff found that the fund used intermediaries, agents, and business partners to pay bribes to high-level government officials in Africa.  According to the SEC’s order, the illicit payments induced the Libyan Investment Authority sovereign wealth fund to invest in Och-Ziff managed funds.  Other bribes were paid to secure mining rights and corruptly influence government officials in Libya, Chad, Niger, Guinea, and the Democratic Republic of the Congo. The SEC’s order finds that Och-Ziff executives ignored red flags and corruption risks and permitted illicit transactions to proceed.


September 28, 2016 – Anheuser Busch

The SEC has announced that Anheuser-Busch InBev has agreed to pay US$6 million to settle charges it violated the Foreign Corrupt Practices Act (FCPA). An investigation found that the company used third-party sales promoters to make improper payments to government officials in India to increase the sales and production of Anheuser-Busch products in that country. The SEC’s order further finds that Anheuser-Busch entered into a separation agreement that stopped an employee from continuing to voluntarily communicate with the SEC about potential FCPA violations due to a substantial financial penalty that would be imposed for violating strict non-disclosure terms. 

September 28, 2016 – Ronald Harper, former Royal deputy property manager

A former Royal Household official who accepted more than  £100,000 in bribes to award contracts for work to royal residences including Buckingham Palace has been jailed for five years. Ronald Harper was the deputy property manager responsible for maintaining the Queen’s main London home, plus St James’s Palace, Clarence House and Windsor Castle. He accepted payments or gifts from the directors of companies who were then given large contracts for maintenance of the historic buildings paid for by the then Civil List, now called the Sovereign Grant. He was found guilty of two counts of conspiracy to make corrupt payments after two trials at Southwark Crown Court in June and August.  

September 20, 2016 – Nu Skin Enterprises, Inc.

The Securities and Exchange Commission has announced that Provo, Utah-based Nu Skin Entreprise, Inc (Nu Skin US) has agreed to pay US$765,688 to settle charges that it violated the internal controls and books-and-records provisions of the Foreign Corrupt Practices Act. The FCPA violations arose from a payment its Chinese subsidiary, Nu Skin (China) Daily Use & Health Products Co. Ltd. (Nu Skin China), made to a charity to obtain the influence of a high ranking Chinese Communist party official to impact an on-going provincial agency investigation.

September 13, 2016 – Jun Ping Zhang

The Securities and Exchange Commission has instituted cease-and-desist proceedings against Jun Ping Zhang, a U.S. citizen and former Chairman and CEO of Harris Corporation’s wholly owned, China-based subsidiary Hunan CareFx Information Technology, LLC. Ping violated the anti-bribery provisions of the FCPA by facilitating an ongoing bribe scheme at CareFx China whereby illegal gifts were given to Chinese government officials to obtain and retain business. In so doing, Ping violated, and caused Harris to violate, the books and records provisions of the FCPA by knowingly allowing and facilitating the entry of false information in CareFx China’s books and records, thereby circumventing Harris’s system of internal accounting controls. 

August 30, 2016 –  AstraZeneca

The Securities and Exchange Commission announced that U.K.-based biopharmaceutical company AstraZeneca PLC has agreed to pay more than $5 million to settle charges that it violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act (FCPA) as a result of its wholly-owned subsidiaries in China and Russia making improper payments to foreign officials.

August 11, 2016 – KEY Energy Services, Inc.

The Securities and Exchange Commission has announced that Houston-based Key Energy Services, Inc. has agreed to pay US$ 5 million in disgorgement to settle charges that it violated the internal controls and books-and-records provisions of the Foreign Corrupt Practices Act (FCPA). The violations arose from payments its Mexican subsidiary, Key Mexico, made to a contract employee at Petroleos Mexicanos (Pemex), Mexico’s state-owned oil company.  

July 25, 2016 – LATAM Airlines Group S.A.

LAN Airlines (now LATAM Airlines Group) has settled charges with the SEC that it failed to keep accurate books and records and maintain adequate internal accounting controls. In 2006 and 2007, Ignacio Cueto Plaza, then CEO of LAN Airlines, allegedly authorized USD 1.15 million in improper payments to a third party consultant in Argentina in connection with LAN Airlines’ attempt to settle labor disputes between LAN Airlines’ subsidiary in Argentina, LAN Argentina, and its employees. The consultant was a Cabinet Advisor in the Ministry of Federal Planning, Public Investment and Service, Department of Transportation. The payments were disguised through a sham consulting agreement. LAN has agreed to pay USD 9.4 million in disgorgement and prejudgment interest and in a non-prosecution agreement announced by the U.S. Deparment of Justice LAN has agreed to pay a USD 12.75 million penalty.

July 11, 2016 – Johnson Controls

Manufacturing company Johnson Controls agree to pay US$14 million to settle Foreign Corrupt Practices Act charges with the Securities and Exchange Commission over conduct in China, while the Justice Department closed its investigation into the matter partly because of extensive cooperation by the company.

July 8, 2016 – SME (not identified due to ongoing legal proceedings)

The UK Serious Fraud Office’s second application for a Deferred Prosecution Agreement has been approved by Lord Justice Leveson at Southwark Crown Court. The counterparty to the DPA is a UK SME that cannot currently be named due to ongoing legal proceedings. As a result of the DPA, the company will pay financial orders of £6.553.085, comprised of a £6,201,085 disgorgement of gross profits and a £32,000 financial penalty. £1.953.085 of the disgorgement will be paid by the SME’s US registered parent company as repayment of a siginificant proportion of the dividends that it received from the SME over the indictment period. 

June 21, 2016 – Analogic Corp.

The Securities and Exchange Commission has announced that Massachusetts-based medical device manufacturer Analogic Corp. and its wholly owned Danish subsidiary have agreed to pay nearly US$ 15 million to settle parallel civil and criminal actions involving Foreign Corrupt Practices Act (FCPA) violations.

June 8, 2016 – Valeant

Valeant has agreed to pay US$ 54 million to settle a 2013 US DOJ investigation into sales and promotional practices related to products that, at the time, were owned by Salix Pharmaceuticals. Valeant bought Salix last year. 

 June 7, 2016 – Akamai Technologies


Akamai Technologies has agreed to pay US$652,452 in disgorgement plus $19,433 in interest in addition to a non-prosecution agreement with the SEC. According to the NPA, Akamai’s foreign subsidiary arranged US$40,000 in payments to induce government-owned entities to purchase more services than they actually needed. Employees at the foreign subsidiary violated the company’s written policies by providing improper gift cards, meals, and entertainment to officials at these state-owned entities to build business relationships. The NPA stipulates that the company will not be charged with violations of the FCPA.

June 7, 2016 – Nortek, Inc.


Rhode Island-based residential and commerical building products manufacturuer Nortek, Inc has agreed to pay $291,403 in disgorgement plus $30,655 in interest in addition to a non-prosecution agreement with the SEC. According to the NPA, approximately $290,000 in improper payments and gifts including cash payments, gift cards, meals, travel, accommodations and entertainment were made to Chinese officials by Nortek’s subsidiary in order to receive preferential treatment, relaxed regulatory oversight, reduced customs duties, taxes, and fees.  The NPA stipulates that the company will not be charged with violations of the FCPA.

May 12, 2016 – Peter Chapman (Innovia Securency)

Peter Chapman, a former manager of polymer banknote manufacturer Innovia Securency PTY, has been sentenced for two and a half years for corruption-related offenses. Chapman was convicted on four counts of making corrupt payments to a foreign official. The Serious Fraud Office had accused Chapman of bribing an agent of Nigerian Security Printing and Minting to convince them to purchase polymer substrate from Chapman’s own company. The total value of the bribes relating to the charges amounts to US$205K (£141K).



May 3, 2016 – Siemens

The German technology giant has agreed to pay US$ 43 million ( €38 million) to settle a corruption case in Israel. Siemens also agreed to appoint an external inspector to supervise its business in Israel. At issue are allegations that Siemens bribed six senior executives of the Israel Electric Corporation (IEC) over ten years ago in a bid to supply turbines. These six individuals now face charges in Tel Aviv for bribery and money laundering, as they are suspected of accepting bribes of hundreds of thousands of dollars in cash or in transfers to Swiss bank accounts.  

April 7, 2016 – Las Vegas Sands

The U.S. Securities and Exchange Commission has announced that Las Vegas Sands Corp. has agreed to pay US$9 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by failing to properly authorize or document millions of dollars in payments to a consultant facilitating business activities in China and Macao.

April 7, 2016 – Giuseppe Orsi and Bruno Spagnolini

The former boss of Italian aerospace and defence group, Finmeccanica, Giuseppe Orsi, was sentenced on April 7 by the Milan appeals court to four and a half years in jail for false accounting and corruption.  Also handed a four-year jail term on the same charges was Bruno Spagnolini, former head of AgustaWestland, a subsidiary of Finmeccanica. The case against the two resulted from an investigation launched in 2012 into the sale of 12 luxury helicopters to India’s government. India cancelled the deal with AgustaWestland in January 2014 amid allegations that the company paid bribes to win the €556 million contract.

April 4, 2016 –  Braid Logistics

Braid Logistics, a Glasgow-based logistics firm has agreed to pay £2.2 million to the Crown after it uncovered illegal bribery operations in its own organisation. An investigation revealed breaches of the UK Bribery Act 2010 which forbids bribes being paid to gain business. Braid sacked those involved and self-reported the case to the Crown Office. 

March 23, 2016 – Novartis AG

Swiss company Novartis AG has agreed to pay US$25 million to settle charges that it violated the Foreign Corrupt Practices Act when two China-based subsidiaries bribed doctors and others to prescribe drugs.

March 3, 2016 – Mikhail Gourevitch, NORDION

The SEC has charged Mikhail Gourevitch with violating the FCPA by scheming to bribe Russian government officials and obtain drug approvals for his then-employer while secretly enriching himself. The SEC also charged the company with lacking sufficient internal controls to detect and prevent the scheme. Gourevitch, whose employment was terminated by Nordion, agreed to settle the charges by paying US$100,000 in disgorgement, $12,950 in prejudgment interest, and a $66,000 penalty.  Nordion agreed to pay a $375,000 penalty to settle charges that it lacked internal accounting controls and basic FPA due diligence to prevent Gourevitch from conducting the scheme. Nordion and Gourevitch consented to SEC orders without admitting or denying the findings that Nordion violated the books-and-records and internal accounting controls provisions of the Securities Exchange Act of 1934 while Gourevitch violated the anti-bribery, books -and-records, and false records provisions.

March 1, 2016 – Olympus Corp. of the Americas


The US’s largest distributor of endoscopes and related equipment will pay US$623.2 million to resolve criminal charges and civil claims relating to a scheme to pay kickbacks to doctors and hospitals. A subsidiary of the distributor will pay US$22.8 million to resolve criminal charges relating to the Foreign Corrupt Practices Act in Latin America.

March 1, 2016 – Qualcomm

The US Securities and Exchange Commission has announced that Qualcomm Incorporated has agreed to pay US$7.5 million to settle charges that it violated the FCPA by hiring relatives of Chinese government officials who played a role in selecting the company’s mobile technology products and for providing gifts, travel, and entertainment to try to influence officials at government-owned telecom companies in China. 

February 19, 2016 – Sweett Group

AIM-listed surveyor becomes first company to be sentenced for bribery over corrupt payments. Sweett Group made corrupt payments to an influential Arab executive to secure work on a luxury hotel project in Dubai. The company received a fine of £1.4 million and an £851,000 confiscation order after it admitted that it had failed to prevent the bribery of Khaled Al Badi.  

February 26, 2016 – TOTAL

French oil company Total SA was fined 750,000 euros (US$826,125) after judges found it guilty of corruption in Iraq’s oil-for-food program. The Paris court of appeals found Total guilty of corrupting foreign civil servants. The penalty comes after Total was cleared of all charges by a Paris court in 2013. 

February 19, 2016 – Vimpelcom

VimpelCom Ltd, an Amsterdam-based telecommunications operator, said on Thursday it would pay $795 million to resolve U.S. and Dutch probes into a bribery scheme in Uzbekistan, in the second largest global anti-corruption settlement in history. The settlement was announced in a federal court in Manhattan, where a subsidiary pleaded guilty to conspiring to violate a U.S. anti-corruption law by paying $114 million in bribes from 2006 to 2012 to a Uzbekistan official. The official, described in court papers as high-ranking and a relative of Uzbek President Islam Karimov, matched the description of his daughter, Gulnara Karimova, who has long been identified as being at the center of the probe.

February 16, 2016 – PTC Inc.

Two subsidiaries of Massachusetts software company PTC Inc. entered into a non-prosecution agreement with the US DOJ and agreed to pay a US$14.54 million penalty to resolve the government’s investigation into whether the companies improperly provided recreational travel to Chinese government officials in violation of the FCPA. In addition, the SEC announced its first deferred prosecution agreement (DPA) with an individual in an FCPA case. FCPA charges will be deferred for three years against Yu Kai Yuan, a former employee of one of PTC’s Chinese subsidiaries, as a result of the significant cooperation he provided during the SEC’s investigation. 

February 4, 2016 – SciClone

SEC announces that California-based SciClone Pharmaceuticals has agreed to pay approximately $12.8 million in connection with charges that it made improper payments to healthcare professionals in China.

February 1, 2016 – SAP

SEC announces that German-based software manufacturer SAP SE (SAP) has agreed to disgorge $3.7 million in profits to settle charges that it violated the FCPA’s accounting provisions in connection with its government sales efforts in Panama. The charges stem from the actions of Vicente Garcia, former head of Latin American sales for SAP International, Inc. who last year pleaded guilty to a criminal information filed by the DoJ and settled civil FCPA charges brought by the SEC.

Cases in 2015

December 8, 2015 – Managers at Direct Access Partners

Sentences have been handed down for employees of Direct Access Partners and participants in a scheme to bribe a Venezuela state bank official.  Jose Alejandro Hurtado was sentenced to 3 years in prison; Tomas Clarke, a former senior vice president received a 2 year sentence and was ordered to forfeit nearly US$5.8 million while the former CEO Benito Chinea and former managing director, Joseph DeMeneses were both sentenced to four years in prison and forfeitures of $3.6 million and $2.7 million. Ernesto Lujan, a former managing partner, also received a two year sentence and was ordered to forfeit $18.5 million.  Direct Access Partners paid bribes to get business from a state-owned development bank in Venezuela, according to allegations by U.S. prosecutors. Both Clarke and Lujan cooperated with prosecutors. The defendants admitted to paying US$5 million to Maria de los Angeles Gonzalez de Hernandez, a vice president at state-owned Banco de Desarollo Economico y Social de Venezuela (Bandes). She has pleaded guilty and will be sentenced in January. 

December 3, 2015 – Pierre Achach

A French Court has sentenced Pierre Achach, a French businessman and number two at Surestream Petroleum,  to a 30 month suspended sentence and a 1.5 million euro fine for fraud,  tax evasion and corruption. The corruption charge results from Mr. Achach’s gift of a return airline ticket (Bujumbura – Paris) to the Burundi Minister of Energy, Moise Bucuni.  

November 30, 2015 –  Standard Bank

SFO – The Serious Fraud Office’s first application for a Deferred Prosecution Agreement has been approved. The counterparty to the DPA, Standard Bank Plc (now known as ICBC Standard Bank Plc) (“Standard Bank”), was the subject of an indictment alleging failure to prevent bribery contrary to section 7 of the Bribery Act 2010. This indictment, pursuant to DPA proceedings, was immediately suspended. This was also the first use of section 7 of the Bribery Act 2010 by any prosecutor.

October 5, 2015 – Bristol-Myers Squibb

The US Securities & Exchange Commission has announced that Bristol-Myers Squibb has agreed to pay more than US$14 million in fines to settle charges that its joint venture in China paid cash and other benefits to state-owned hospitals in exchange for prescription sales. BMS also agreed to report to the SEC for two years on the status of its implementation of FCPA and anti-corruption compliance measures.

September 29, 2015 – Hyperdynamics Corporation

The US SEC has accepted a settlement offer from Hyperdynamics Corp. to resolve allegations of foreign bribery violations. The Houston-based oil and gas exploration company agreed to pay a US$75,000 civil penalty. The SEC alleged in a cease-and-desist order that Hyperdynamics failed to accurately record payments made by a Guinean subsidiary, a violation of the books-and-records provision of the FCPA. The SEC took into consideration the remedial actions undertaken by the company and the cooperation it afforded the Commission. In May the company was cleared of FCPA allegations by the US DOJ.

September 28, 2015 – Hitachi, Ltd.

The Securities and Exchange Commission has charged Toyko-based conglomerate Hitachi, Ltd. with violating the Foreign Corrupt Practices Act (FCPA) when it inaccurately recorded improper payments to South Africa’s ruling political party in connection with contracts to build two multi-billion dollar power plants. Hitachi has agreed to pay $19 million to settle the SEC charges.

September 25, 2015 – Brand Rex

The Scottish Civil Recovery Unit recovered £212,800 under an agreed civil settlement with a Glenrothes based company which accepted that it had benefited from unlawful conduct by a third party. Brand-Rex Limited is a developer of cabling solutions for network infrastructure and industrial applications. In June 2015, solicitors acting on behalf of Brand-Rex contacted the Crown Officer to disclose an instance of failing to prevent bribery by a third party associated with the company.

August 31, 2015 – Daren Condrey

Daren Condrey, 50, pleaded guilty on June 17, 2015 to conspiring to violate the FCPA and will be sentenced on November 2, 2015. Mr Condrey’s offense is connected to a case where Russian official, Vadim Mikerin, of Chevy Chase, Maryland, pleaded guilty to conspiracy to commit money laundering  in connection with his role in arranging over US$ 2 million in corrupt payments to influence the awarding of contracts with the Russian state-owned nuclear energy corporation.

August 18, 2015 – BNY Mellon

The Securities and Exchange Commission has announced that BNY Mellon agreed to pay US$14.8 million to settle charges that it violated the Foreign Corrupt Practices Act (FCPA) by providing valuable student internships to family members of foreign government officials affiliated with a Middle Eastern sovereign wealth fund.

August 12, 2015 – Vicente E. Garcia, former VP SAP SE

The SEC has announced that a former executive for a worldwide software manufacturing company has agreed to settle charges that he violated the FCPA by bribing Panamanian government officials through an intermediary to procure software license sales. Vicente Garcia, former VP of global and strategic accounts for SAP SE consented to the entry of the cease-and-desist order and agreed to pay disgorgement of US$85,965 which is the total amount of kickbacks he received plus prejudgment interest  of US6,430 for a total of US$92,395. In a parallel action the US DOJ announced a criminal action against Garcia to which he has pleaded guilty. In December he was sentenced to 22 months in prison.

July 28, 2015 – Mead Johnson Nutrition

The SEC has announced that Mead Johnson Nutrition Company will settle charges that its Chinese subsidiary made improper payments to health care professionals at government-owned hospitals to recommend the company’s infant formula to patients who were new or expectant mothers in violation of the FCPA. Mead Johnson Nutrition has agreed to pay US$ 12 million to settle the SEC’s finding.

July 17, 2015 – Louis Berger International

Louis Berger International, the New Jersey-based engineering, architecture and construction management company entered into a deferred prosecution agreement (DPA) with the DOJ, admitting to violations of the FCPA. LBI agreed to pay a US$17.1 million criminal penalty and to implement rigorous internal controls, including retention of a compliance monitor for at least three years.

June 16, 2015 – Joseph Sigelman, former co-chief executive officer of PetroTiger Ltd.

The former co-chief executive officer (CEO) of PetroTiger Ltd. – a British Virgin Islands oil and gas company with operations in Colombia and formerly with an office in New Jersey – pleaded guilty to conspiring to pay bribes to a foreign government official in violation of the Foreign Corrupt Practices Act (FCPA). Joseph Sigelman is the third former PetroTiger executive to plead guilty in the case. The case was brought to the attention of the DOJ through a voluntary disclosure by PetroTiger, which cooperated fully with the DOJ’s investigation. Mr Sigelman was sentenced to probation and ordered to pay a US$100,000 fine and US$239,015 in restitution.

June 17, 2015 – IAP Worldwide Services Inc.

Florida based defense company IAP Worldwide Services Inc will pay US$7.1 million to settle a U.S. investigation into an alleged conspiracy to bribe Kuwaiti officials to win a government contract, the US Department of Justice has said. In addition, a former vice president of IAP has pleaded guilty to conspiracy to violate the FCPA for  his involvement in the bribery scheme.

May 20, 2015 – BHP Billiton

The US Securities and Exchange Commission has charged global resources company BHP Billiton with violating the FCPA when it sponsored the attendance of foreign government officials at the Summer Olympics in China. BHP Billiton has agreed to pay a US$ 25 million penalty to settle the SEC’s charges.

May 7, 2015 – The Algiers Criminal Court

An Algerian court sentenced to jail 14 people and fined seven foreign firms from Europe, Asia and Canada capping a high-profile corruption case. The Algiers criminal court sentenced to 10 years Chani Mejdoub, a financial consultant who also holds Luxembourg nationality, and Mohamed Khelladi, a former high-ranking official at the ministry of public works. A business man and another former official at the public works ministry were sentenced to seven years in jail each and three year sentences were handed down to two other defendants. Seven firms – including from China, Japan, Switzerland, Canada, Spain and Portugal – were each fined €50 000.

April 22, 2015 – SEC

The US Securities and Exchange Commission (SEC) has announced the award of more than a million dollars to a compliance professional who provided information that assisted the SEC in an enforcement action against the whistleblower’s company.

April 8, 2015 – FLIR

The SEC charged Oregon-based FLIR Systems Inc. with violating the FCPA by financing what an employee termed a “world tour” of personal travel for government officials in the Middle East who played key roles in decisions to purchase FLIR products. FLIR has agreed to settle the US SEC’s charges by paying more than US$9.5 million and reporting its FCPA compliance efforts to the agency for the next two years.

March 18, 2015 – Biomet Inc.

Orthopedic device maker Biomet Inc. said in an SEC filing that the DOJ has extended for another year its 2012 deferred prosecution agreement that was part of a 2012 FCPA enforcement action.

February 24, 2015 – Goodyear

The US SEC charged Goodyear Tire & Rubber Company with violating the FCPA when its subsidiaries paid bribes to land tire sales in Kenya and Angola. Goodyear agreed to pay more than US$ 16 million to settle the  SEC’s charges.

January 22, 2015 – The PBSJ Corporation

The Securities and Exchange Commission charged a former officer at a Tampa, Florida-based engineering and construction firm with violating the FCPA by offering and authorizing bribes and employment to foreign officials to secure Qatari government contracts. The PBSJ Corporation will enter into a two year deferred prosecution agreement and pay the SEC US$3.4 million in disgorgement and interest while the former officer involved in the scheme will pay a fine of US$50,000.

Cases in 2014 

December 22, 2014 – Smith & Ouzman and Christopher John Smith and Nicholas Charles Smith

The UK Serious Fraud Office announces conviction of Christopher John Smith (chairman) and Nicholas Charles Smith (sales and marketing director) of making £395,074 in corrupt payments to officials in Kenya and Mauritania to win contracts.


December 21, 2014 – Alstom SA

Alstom S.A., a French power and transportation company, pleaded guilty and has agreed to pay a US$772 million fine to resolve charges related to a widespread scheme involving tens of millions of dollars in bribes in countries around the world including Indonesia, Saudi Arabia, Egypt and the Bahamas.

December 17, 2014 – AVON Products (China)

Avon Products (China) Co. Ltd. (Avon China), a wholly owned subsidiary of the New York-based cosmetics company, Avon Products Inc. (Avon), pleaded guilty to conspiring to violate the accounting provisions of the FCPA to conceal more than US$8 million in gifts, cash and non-business meals, travel and entertainment it gave to Chinese government officials in order to obtain and retain business benefits for Avon China. Avon entered into a deferred prosecution agreement to resolve the investigation. Avon will pay US$67,6 million in criminal penalties and $67,3 million in fines to the SEC for a total of $135 million in penalties. It has also agreed to implement rigorous internal controls and retain a compliance monitor for at least 18 months.

December 16, 2014 – Bruker Corp

Life sciences company Bruker Corp. agreed to pay US$2.4 million to settle U.S. charges that it bribed Chinese government officials to win business. An investigation by the SEC found that Bruker, based in Billerica, Mass, lacked controls to prevent and detect about US$230,000 in payments out of its China-based offices that helped the company earn US$1.7 million in profits from sales contracts with state-owned entities in China.

December 11, 2014 – Rheinmetall Defense Electronics

Rheinmetall Defense Electronics, a subsidiary of German defence contractor Rheinmetall, has settled a foreign bribery investigation with Bremen’s public prosecutor and agreed to pay a €37 million penalty.

December 10, 2014 – Dallas Airmotive Inc.

Dallas Airmotive Inc., a provider of aircraft engine maintenance, repair and overhaul services based in Grapevine, Texas has admitted to violations of the FCPA and agreed to pay a US$14 million penalty to resolve charges that it bribed Latin American government officials in order to secure lucrative government contracts.

November 17, 2014 – former employees of FLIR

The SEC sanctioned two former employees in the Dubai office of US based FLIR for violating the FCPA by taking government officials in Saudi Arabia on a “world tour” to help secure business for the company.  The employees, Stephen Timms and Yasser Ramahi, also gifted the officials with luxury watches. Timms and Ramahi consented to the entry of the order and agreed to pay financial penalties of US$50,000 and US$20,000 respectively. Prior to providing the gifts and travel to the Saudi Arabian officials, Ramahi and Timms each had taken FCPA  training at the company that specifically identified luxury watches and side trips as prohibited gifts.

November 12, 2014 – SBM Offshore

Oil platform services company SBM Offshore has agreed to a US$240 million foreign bribery settlement with Dutch prosecutors, while the US DOJ has dropped its parallel FCPA investigation of the matter.


November 3, 2014 – Bio-Rad

The SEC charged a clinical diagnostic and life science research company based in California with violating the FCPA when its subsidiaries made improper payments to foreign officials in Russia, Vietnam, and Thailand in order to win business. Bio-Rad, which self-reported its misconduct and cooperated extensively during the investigation, has agreed to pay US$ 55 million to settle the SEC’s charges and a parallel action by the US DoJ.

October 27, 2014 – Layne Christensen Company

The SEC has charged global water management, constuction, and drilling company Layne Christensen, based in Texas, with violating the FCPA by making improper payments to foreign officals in several African countries in order to obtain beneficial treatment and reduce its tax liability. Layne has agreed to pay more than US$ 5 million to settle the SEC’s charges.

September 27, 2014 – Cy Tokmakjian, Tokmakjian Group

Cy Tokmakjian, President of Canadian company, Tokmakjian Group, has been given a 15-year sentence in Cuba. Cuba’s Communist Party newspaper Granma has said that Tokmakjian was accused of corruption to obtain benefits in contract negotiations and other offenses. The Tokmakjian Group has stated that Tokmakjian was held without charge for 2 years while the results of the investigation were kept secret and then he was just given 2 months to present a defense. The company insists that they were “legitimate commercial transactions.”

September 19, 2014 – GlaxoSmithKline

China has fined GlaxoSmithKline 3 billion yuan (US$489 million) for paying bribes to doctors to use its drugs. A court in the city of Changsha handed suspended sentences of between two and four years to Mark Reilly, the former head of GSK in China and four other GSK executives.

July 28, 2014 – Smith & Wesson

The US SEC has charged Smith & Wesson Holding Corporation with violating the FCPA when employees and representatives of the US based parent company authorized and made improper payments to foreign officials while trying to win contracts to supply firearm products to military and law enforcement overseas. Smith & Wesson has agreed to pay US$2 million to settle the SEC’s charges.

July 25 10, 2014 – Frederic Cilins

[DOJ] Frederic Cilins, 51, a French citizen, who, in March, had pleaded guilty in the Southern District of New York to obstructing a federal criminal investigation into whether a mining company paid bribes to win lucrative mining rights in the Republic of Guinea has been sentenced to 24 months in prison.

July 22, 2014 – Bruce Hall

Bruce Hall has been sentenced to 16 months in prison for conspiracy to corrupt, in relation to contracts for the supply of goods and services to a Bahraini company, Aluminum Bahrain B.S.C. (Alba) where he had served as CEO from September 2001 to June 2005. As a result of these corrupt payments, Mr Hall will need to pay a confiscation order of just over £3 million in seven days or face serving an additional term of imprisonment of 10 years. He must also pay Alba compensation in the amount of £500,010 and pay £100,000 in court costs.

July 18, 2014 – Pemex vs Siemens, SK Engineering JV

A US federal appeals court has denied an attempt by Mexican state-owned oil company Pemex to recover damages from a Siemens-managed joint venture following alleged bribery, as the matter lacked a sufficient connection to the United States. The US Court of Appeals for the Second Circuit said Pemex’s claim under the Rackateer Influenced and Corrupt Organisations (RICO) Act alleged conduct which took place mainly in Mexico even though Pemex had claimed that the Siemens scheme to bribe Pemex employees involved finance secured in the US and links to the US banking system.

June 18, 2014 – Innospec

A jury in Southward Crown Court today convicted Dennis Kerrison and Miliades Papachristos of conspiracy to commit corruption, following an investigation conducted by the Serious Fraud Office. The convictions of Mr Kerrison, a former CEO of Associated Octel Corporation (subsequently renamed Innospec Limited) and Dr Papachristos, former Regional Sales Director for the Asia Pacific region, complete the SFO’s six year investigation into Innospec, which led to two other individuals and Innospec entering guilty pleas.

June 16, 2014 – Elena Kotova, formerly European Bank for Reconstruction and Development

A Russian court handed the country’s former top representative at the European Bank for Reconstruction and Development a suspended sentence after finding her guilty of seeking a bribe of more US$1.4 million. A former Russian banker, Igor Lebedev, was also found guilty of acting as a go-between for Kotova in the attempted bribe-seeking and was given a four-year suspended term. Kotova had demanded the payment in return for facilitating a US$95 million loan by the London-based international lender to a Canadian oil and gas company, according to Russian investigators.

May 28, 2014 – Snamprogetti

Snamprogetti Netherlands B.V. agreed to pay the Africa Development Bank US$5.7 million in penalties for bribery related contracts for liquefied natural gas production plants on Bonny Island, Nigeria.

May 16, 2014 – United States Court of Appeals for the 11th Circuit decision

The appeal is the first time that an appellate court has weighed in on the prominent enforcement theory that employees of alleged state-owned or state-controlled entities are “foreign officials” under the FCPA

May 1, 2014 – AVON

Beauty products company AVON has reached a settlement with the US DOJ and SEC for FCPA offenses. The company will pay US$135 million ($68 million to the DOJ and $67 million to the SEC) for “alleged violations of the books and records and internal control provisions of the FCPA.”

April 14, 2014 – Alstom Marubeni bribery case

Indonesia’s main anti-corruption court sentenced a lawmaker to three year’s jail for having accepted bribes in 2004 from French company Alstom and Japan’s Marubeni in a multimillion dollar contract.

April 9, 2014 – Hewlett-Packard

[SEC] The Securities and Exchange Commission has charged Hewlett-Packard with violating the Foreign Corrupt Practices Act (FCPA) when its subsidiaries in three different countries made improper payments to government officials to obtain or retain lucrative contracts.

March 28, 2014 – SWECO

The World Bank has debarred SWECO Environment AB and its affiliates and has conditionally non-debarred SWECO International AB and its affiliates for three years following SWECO AB’s acknowledgment of misconduct in relation to an urban infrastructure project in Eastern Europe. Two former SWECO Environment AB employees paid for a trip for the Head of Project Management Unit and his family during the procurement process for two World Bank-financed contracts in exchange for confidential information from the technical proposals of other consultants competing for the same contracts.

March 19, 2014 – Marubeni

[DOJ] Marubeni Corporation, a Japanese trading company involved in the handling of products and provision of services in a broad range of sectors around the world entered a plea of guilty on March 19, 2014 for its participation in a scheme to pay bribes to high-ranking government officials in Indonesia to secure a lucrative power project.

February 27, 2014 – Ahmad al-Wahaibi

A court in Oman sentenced the CEO of state-owned Oman Oil Company to 23 years in jail for taking US$8 million in bribes from a senior official at a South Korean company

February 4, 2014 – Siemens executives

[SEC] Judge Shira Scheindlin of the Southern District of New York entered a default judgment against two former Siemens AG executives under the FCPA for their roles in a decade-long bribery scheme in which Siemens paid US$100 million in bribes to obtain a US$1 billion contract from the Argentine government. The judgment requires defendants Stephan Signer and Ulrich Bock, who served as the Siemens officials in charge of the contract, to pay a civil penalty of US$524,000 each, and obligates Bock to disgorge an additional US$413,957. These penaltes are among the highest ever levied against individuals under the FCPA

January 15, 2014 – Yara International ASA

Norway’s economic crimes authority has found fertilizer supplier Yara guilty of corruption involving deals in Libya, India and Russia and ordered it to pay 295 million kroner (€35,3M) in fines. The world’s biggest supplier of nitrogen fertilizers acknowledged that it had paid out bribes in the three countries totaling more than 70 million kroner (€8,4M) from 2004 to 2009.

January 13, 2014 – KPMG

On December 30, 2013 KPMG reached a €7 million settlement with the Dutch authorities. The total settlement consists of a fine of €3.5 million and a forfeiture of €3.5 million. It was alleged that KPMG helped its client, Ballast Nedam, disguise suspicious payments. Ballast Nedam itself settled with the Dutch authorities for €17.5 million in 2012.

January 9, 2014 – Alcoa Inc.

Alcoa Inc. and Alcoa World Aluminium have agreed to settle the US SEC’s charges and a parallel criminal case by paying a total of US$384 million. The SEC had charged the global aluminium producer of violating the FCPA when its subsidiaries repeatedly paid bribes to government officials in Bahrain to maintain a key source of business.

Cases in 2013, by date and by company:

December 20, 2013 – Archer Daniels Midland

The US SEC charged ADM for failing to prevent illicit payments made by foreign subsidiaries to Ukrainian government officials in violation of the FCPA. A SEC investigation found that ADM’s subsidiaries in Germany and Ukraine paid $21 million in bribes through intermediaries to secure the release of value-added tax refunds. ADM agreed to pay more than $36 million to settle the SEC’s charges.

In a parallel action, the US DOJ announced a non-prosecution agreement with ADM and criminal charges against an ADM subsidiary that has agreed to pay $17.8 million in criminal fines.

December 9, 2013 – Bilfinger SE

Bilfinger SE, an international engineering and services company based in Mannheim, Germany, has agreed to pay a US$32 million penalty to resolve charges that it violated the Foreign Corrupt Practices Act (FCPA) by bribing government officials of the Federal Republic of Nigeria to obtain and retain contracts related to the Eastern Gas Gathering System (EGGS) project, which was valued at approximately US$387 million.

November 26, 2013 – Weatherford International Limited

Three subsidiaries of Weatherford International Limited (Weatherfield International), a Swiss oil services company that trades on the New York Stock Exchange, have agreed to plead guilty to anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA) and export controls violations under the International Emergency Economic Powers Act (IEEPA) and the trading with the Enemy Act (TWEA). Weatherford International and its subsidiaries have also agreed to pay more than US$252 million in penalties and fines. With respect to the requirement for a monitor the US government said it plans to rely on a monitor for at least 18 months of the roughly three-year deferred prosecution agreement tied to the bribery probes, but will let the firm self-report to regulators after that.

October 24, 2013 – Stryker

The US Securities and Exchange Commission charged Stryker, a medical technology company based in Michigan, with violating the FCPA when subsidiaries in five different countries (Argentina, Greece, Mexico, Poland, Romania) bribed doctors, health care professionals and other government-employed officials in order to retain or obtain business. Stryker has agreed to pay more than $13.2 million to settle the SEC’s charges.

October 22, 2013 – Diebold Inc.

The SEC has charged Diebold Inc, maker of ATMs and bank security systems, with violating the FCPA by bribing officials at government owned banks in China and Indonesia. Diebold has agreed to pay more than $48 million to settle the charges. Diebold will also settle a parallel criminal matter with the US Department of Justice.

The SEC further alleges that from 2005 to 2008, Diebold’s Russian subsidiary paid approximately $1.2 million in bribes in connection with the sale of ATMs to private banks in Russia. Diebold has agreed to pay $22.9 million in disgorgement and prejudgment interest and appoint an independent compliance monitor in order to settle the charges.

October 21, 2013 – Siemens AG

A U.S. judge has thrown out a lawsuit accusing Germany’s Siemens AG of funneling kickbacks to Chinese and North Korean hospital officials, narrowing the ability of plaintiffs to use U.S courts to sue over conduct outside the country. U.S District Judge William Pauley said that the anti-retaliation provision of the 2010 Dodd-Frank Act which protects whistleblowers from discipline for reporting alleged violations by their employers, did not apply to conduct outside the United States. The suit had been brought by a former Siemens employee in China.

September 2013 – Bo Xilai

Bo Xilai, former Poliburo member and Secretary of the Communist Party’s Chongqing branch, was found guilty of corruption in China and sentenced to life in prison. Bo received the sentence for taking 26.8M yuan (€3.2M) in bribes. He is appealing the decision. October 25, 2013 Bo’s appeal rejected by the high court in Shandong province.

August 15, 2013 – Nazir Karigar

Nazir Karigar, an Indian-born Canadian high-tech executive has been found guilty by a Canadian court of conspiring to bribe several government officials in India, including a former aviation minister. The bribes were to help CryptoMetrics, an upstart U.S. high-tech security company with an office in Ottawa, secure a contract for their facial recognition security system with Air India. It is the first conviction of an individual under the Corruption of a Foreign Public Official Act. Three other convictions were of corporate defendants. Mr Karigar faces up to 14 years in prison.

June 11, 2013 – Saipem

A court in Milan has fined Saipem SpA €600,000 (US$780,000) and ordered the confiscation of €24 million of assets after finding Italy’s biggest oil services company guilty of corruption in Nigeria. The fine covers actions which apparently ended in 2001. Saipem is appealing.

June 5, 2013 – Patria / Slovenia

Janez Jansa, former prime minister of Slovenia, was convicted of corruption for soliciting bribes and sentenced to two years in prison. Claiming that the charges were politically motivated, Jansa said he would appeal.

The District Court ruled that Jansa and two others had tried to obtain a commission of two million euros from Patria, a Finnish firm, in relation to a contract for armored personnel carriers in 2006.

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May 29, 2013 – TOTAL S.A.

Total, S.A., a French oil and gas company that trades on the NY Stock Exchange, has agreed to pay the DOJ a $245.2 million monetary penalty to resolve charges related to violations of the Foreign Corrupt Practices Act (FCPA) in connection with illegal payments made through third parties to a government official in Iran to obtain valuable oil and gas concessions. In addition, the SEC has entered into a cease-and-desist order against Total in which the company agreed to pay $153 million in disgorgement and prejudgment interest.

May 6, 2013 – Paul Novak

A former consultant for a unit of Willbros Group Inc. was sentenced to 15 months in prison for his role in a bribery conspiracy. Paul Novak, who pleaded guilty to one count of violating the FCPA and one count of FCPA conspiracy, was also ordered to pay a $1 million fine, and to serve two years of supervised release. Novak admitted that from 2003 to March 2005 he conspired with others to make a series of payments totalling $6 million to various Nigerian government officials and political party leaders to help Willbros and its joint venture partner get a gas project valued at nearly $400 million.

In addition to Novak, two Willbros employees have pleaded guilty in the case, and Willbros entered into a deferred prosecution agreement.

April 22, 2013 – Ralph Lauren Corporation

The US SEC announced a non-prosecution agreement (NPA) with Ralph Lauren Corp. in which the company will disgorge more than $700,000 in illicit profits and interest obtained in connection with bribes paid by a subsidiary to government officials in Argentina from 2005 to 2009. The SEC decided not to charge Ralph Lauren Corporation with violations of the FCPA due to the company’s prompt reporting of the violations of its own initiative, the completeness of the information provided, and its extensive, thorough and real-time cooperation with the SEC investigation. Ralph Lauren Corp has also entered into an NPA with the US DOJ and agreed to pay an $882,000 penalty to resolve the FCPA violation allegations.

April 16, 2013 – Parker Drilling

Parker Drilling Co. agreed to pay U.S. authorities US$15.85M to settle foreign bribery charges. The Houston based drilling-services company authorized payment to a third party knowing it would be used to influence a Nigerian government panel’s decision as it reviewed the company’s adherence to local customs and tax laws.

April 16, 2013 – Uriel Sharef

Uriel Sharef, who served on Siemens‘ managing board from 2000 to 2007, entered in to a settlement with the SEC on April 12, 2013. Sharef agreed to pay the $275,000 fine without admitting or denying the charges against him.

April 2013 – Royal Philips Electronics NV (PHIA)

Royal Philips Electronics NV was fined $4.5 million by the US Securities and Exchange Commission because of alleged bribery in Poland. According to the SEC the Philip’s violations relate to improper payments made by employees of Philips’s Polish subsidiary, Philips Polska sp. The violations took place through Philips’s operations in Poland from at least 1999 through 2007.

January 22, 2013 – Griffiths Energy (Canada)

The energy company founded by the late Bay Street financier Brad Griffiths pleaded guilty to bribery charges and agreed to pay a CDN$10.35 million penalty – the largest fine the RCMP has garnered since establishing specialized teams to investigate foreign corruption.

The plea by Griffiths Energy International Inc. stands to settle charges it faces under Canada’s Corruption of Foreign Public Officials Act after a company investigation unearthed payments made in an attempt to secure lucrative energy properties in Chad in 2009.

Cases in 2012, by date and by company:

December 20, 2012 – Eli Lilly

The US Securities and Exchange Commission (SEC) charged Eli Lilly and Company with violations of the Foreign Corrupt Practices Act (FCPA) for improper payments its subsidiaries made to foreign government officials to win millions of dollars of business in Russia, Brazil, China and Poland. Eli Lilly agreed to pay $29M to settle the civil charges.

December 17, 2012 – Allianz SE

The SEC charged Germany-based insurance and asset management company Allianz SE with violating the books and records and internal controls provisions of the FCPA for improper payments to government officials in Indonesia during a seven-year period. Allianz agreed to pay more than $12.3M to settle the charges which included the acquiring or retention of contracts by improper payments of $650,626 by Allianz’s subsidiary in Indonesia to employees of state-owned entitites.

December 12, 2012 – ZTE/Huawei

A former director of Algeria Telecom and an Algerian/Luxembourgish businessman were sentenced to 15 years in prison and ordered to pay €40,000 in fines by an Algerian court for money laundering after they accepted bribes from ZTE Algeria and Huawei Algeria, two Chinese telecom companies, who paid bribes in order to secure telecoms contracts in Algeria. In addition, ZTE’s Dong Zao and Chen Zhibo and Huawei’s Xiao Chunfa were accused of bribery, found guilty and sentenced in abstentia to ten years in prison and fined $65,000. It seems unlikely that China will extradite them.

November 29, 2012 – Abbot Group Limited

The Civil Recovery Unit in Scotland is to recover £5.6 million under Proceeds of Crime legislation after Abbot Group Ltd accepted that it had benefited from unlawful conduct. Abbot Group Limited (“Abbot”), which is based in Aberdeen, admitted that it had benefited from corrupt payments made in connection with a contract entered into by one of its overseas subsidiaries and an overseas oil and gas company.

November 8, 2012 – Control Components

The former president and CEO of industrial valve maker Control Components Inc. was sentenced to four months in prison for his role in a foreign bribery scheme, while the company’s former sales manager received three month’s probation. The married couple pleaded guilty in April to making a corrupt payment to an official of a foreign government in violation of the Foreign Corrupt Practices Act.

November 02, 2012 – Blackstone Medical Inc.

{DOJ} Orthofix subsidiary, Blackstone Medical Inc., has agreed to pay the United States $30 million to settle allegations that it paid illegal kickbacks to physicians in order to induce use of the company’s products. Orthofix, which manufactures spinal implants and other spinal surgery products, is a publicly traded company headquartered in Curacao.

September 24, 2012 – TYCO

[SEC] Tyco International Ltd. – together with a subsidiary that pleaded guilty to a criminal charge for conspiring to violate the FCPA – has agreed to pay more than US$26 million to resolve the conspiracy charge wth the Department of Justice and charges with the US Securities and Exchange Commission.

September 5, 2012 – SAFRAN

The French security and defense firm Safran was convicted and ordered to pay 500 000 euros in penalties by a Paris court for bribes paid by Sagem to Nigerian officials between 2000 and 2003. Sagem, which merged with Snecma in 2005 to form Safran, obtained a contract in 2001 for 70 million identification cards in Nigeria. The former sales director for Nigeria as well as another manager were acquitted. Safran is appealing.

August 2012 – US Security and Exchange Commission

[SEC] The Securities and Exchange Commission has issued the first award under a new whistleblower bounty program created by the Dodd-Frank Act The award, for an informant who helped the SEC stop a multi-million-dollar fraud, was nearly $50 000. It represents 30% of the amount collected in an enforcement action, the maximum allowed under the law.

August 22, 2012 – US Securities and Exchange Commission

[SEC] The SEC adopted rules mandated by the Dodd-Frank Wall Street Reform and Consumer Protection Act requiring resource extraction issuers to disclose certain payments made to the US govenment or foreign governments.

August 16, 2012 – ORACLE

[SEC] The Securities and Exchange Commission charged Oracle Corporation with violating the Foreign Corrupt Practices Act (FCPA) by failing to prevent a subsidiary from secretly setting aside money off the company’s books that was eventually used to make unauthorized payments to phony vendors in India. Oracle agreed to pay a £2 million penalty to settle the SEC’s charges.

August 7, 2012 – Pfizer

[DOJ] Pfizer H.C.P. Corporation, an indirect and wholly subsidiary of Pfizer Inc., has agreed to pay a US$15 million penalty to resolve an investigation of FCPA violations. In a related matter, Pfizer Inc., and Wyeth LLC reached settlements with the SEC under which Pfizer Inc. agreed to pay more than US$26.3 million in disgorgement of profits to resolve concerns involving the conduct of its subsidiaries. “Pfizer took short cuts to boost its business in several Eurasian countries, bribing government officials in Bulgaria, Croatia, Kazakhstan and Russia to the tune of millions of dollars,” said Principal Deputy Assistant Attorney General Mythili Raman.

August 9, 2012 Victoria Supreme Court (Australia) – Andrew Lindberg

A Victoria Supreme Court judge delivered his judgement on Andrew Lindberg, former chief executive of the Australian Wheat Board, after the former executive reached a deal with the Australia Securities and Investments Commission. Mr. Lindberg was one of the executives at the helm of the wheat board when it paid more than $100AUS million in bribes to the Iraqi government of Saddam Hussein. Mr Lindberg admitted to four contraventions of the Corporations Act involving his failure to exercise reasonable care and skill in his role. Justice Robson found the agreed penalty of $100 000 AUS and disqualification from managing a corporation until 14 September 2014 were appropriate punishments at the upper end of the possible range.

July 30, 2012 – INNOSPEC

[SFO] Former CEO of Innospec Ltd pleads guilty to conspiracy charges brought by the Serious Fraud Office. Paul W. Jennings, who resigned as CEO on 20 March 2009, pleaded guilty in Southwark Crown Court on 30 July 2012 to one charge of conspiracy to corrupt Iraqi public officials between June 2006 and May 2007. The corrupt payments served as inducements to ensure that tests on a competitor product conducted by or on behalf of the Government of Iraq concluded unfavorably. Earlier, on 11 June 2012, Jennings pleaded guilty to conspiracy to corrupt public officials in Indonesia between 2002 and 2008, and in Iraq between 2003 and 2009, in order to secure contracts for the supply of Innospec products such as tetraethyl lead.

Another Innospec executive, David Turner, also pleaded guilty to similar charges in Iraq and Indonesia in January of this year, while two others, Miltos Papachristos and Dennis Kerrison, have pleaded not guilty.

Innospec Inc. and its wholly-owned subsidiary in the UK, Innospec Limited, were part of a global settlement concluded between the company, the SEC, the DOJ, and the SFO in 2010.

July 17, 2012 – The Nordam Group Inc.

[DOJ] The Nordam Group Inc., a provider of aircraft maintenance, repair and overhaul (MRO) services based in Tulsa, Oklahoma, has entered into an agreement with the US DOJ to pay a $2M penalty to resolve violations of the FCPA. Nordam, its subsidiaries and affiliates paid bribes to employees of airlines created, controlled and exclusively owned by the People’s Republic of China in order to secure contracts to perform MRO services for those airlines. The bribes were paid both directly and indirectly to the airline employees.

July 10, 2012 ORTHOFIX

[DOJ, SEC] The producer of orthopaedic products, ORTHOFIX, was convicted and ordered to pay $2.22M in criminal fines to the US DOJ and $5.2M to the SEC in disgorgement and pre-judgement interest for bribing public officials of a Mexican government-owned healthcare and social services institution in order to obtain contracts. The wholly-owned subsidiary of ORTHOFIX, Promeca, bribed IMSS employees with cash and gifts directly and through front companies owned by the officials. ORTHOFIX concluded a three year deferred prosecution agreement with the DOJ.

July 6, 2012 Patrick Joseph

[DOJ] Patrick Joseph, former General Director for Telecommunications at the state-owned Telecommunications d’Haiti (Haiti Telco) was sentenced to 12 months and one day in prison for money-laundering in the corruption case involving Florida telecommunications companies, including Terra Telecommunications, whose former CEO was convicted and sentenced to 15 years in prison.

July 3, 2012 Oxford University Press

[SFO, World Bank] Two wholly-owned subsidiaries of Oxford University Press were debarred for three years by the World Bank for bribing public officials in east Africa in order to obtain two contracts for supplying text books through a project financed by the World Bank.

In addition to the debarment, Oxford University Press agreed to pay $500K to the World Bank as part of the settlement and £1.9M to the Serious Fraud Office as part of a negotiated civil settlement.

June 27, 2012, Glencore Grain and Karel Brus

A Belgian court convicted a subsidiary of commodities trader Glencore and others of bribing a European Union official in return for market-sensitive information. Glencore was fined $623,000. Glencore Grain Rotterdam, part of the world’s largest diversified commodities trader, was found guilty of paying the official’s large mobile phone bills and laying on a French holiday to secure information about grain subsidies. The court also convicted other companies and individuals, including French agricultural cooperative Union Invivo, of providing or facilitating bribes. Karel Brus was sentenced to 40 months in jail.

June 27, 2012, Falconstor

[SEC] As part of a commercial bribery scheme Falconstor, acting primarily through the company’s co-founder and then-chief executive officer, president and chairman, made materially misleading statements on earnings calls and in earnings releases, failed to accurately record the expenses associated with the bribes on its books and records, failed to devise or implement a system of effective internal accounting controls to detect or prevent the bribes, which violated state law and were inconsistent with the company’s policies, and granted stock and options in unregistered, non- exempt transactions.

June 27, 2012 Gerhard Gribkowsky

Gerhard Gribkowsky, the German banker who confessed to taking up to £28M in bribes from Bernie Ecclestone in connection to the 2006 sale of Formula One to private equity has been jailed for eight-and-a-half years. He was convicted by a German court of tax evasion, bribery and breach of fiduciary duty over his involvement in the controversial sale of F1 to CVC in 2005. Gribkowsky admitted to receiving 28 million pounds in corrupt payments during the sale of German bank Bayern LB’s stake in Formula 1 to CVC Capital Partners.

June 18, 2012 – Data Systems and Solutions

[DOJ] Data Systems & Solutions LLC (DS&S), based in Reston, Virginia, USA, has agreed to pay an $8.82 million criminal penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA), announced Principal Deputy Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division and U.S. Attorney for the Eastern District of Virginia Neil H. MacBride. According to court documents, DS&S paid bribes to officials employed by the Ignalina Nuclear Power Plant, a state-owned nuclear power plant in Lithuania, to secure contracts to perform services for the plant.

June 1, 2012 – Ao Man-long

Macau’s top court found former official Ao Man-long guilty of nine additional counts of bribery and money laundering, extending his jail sentence by six months to a total of 29 years in the former Portuguese enclave’s most high-profile corruption scandal.

Among the charges, the Macau Court of Final Appeal found that Mr. Ao, the city’s former secretary for transport and public works, was guilty of helping, in 2005, companies run by Hong Kong tycoon Joseph Lau and businessman Steven Lo to win a government tender for five plots of land near the Macau International Airport, in return for a 20 million HK dollar (US$2.5M) bribe.

May 30, 2012 Ascedon Corporation Company

(World Bank) The World Bank declared the Thailand based company, Ascedon Corporation, ineligible to receive contracts for any Bank-financed or Bank-executed project or program governed by the Bank’s Procurement guidelines, Consultant guidelines or Anti-corruption guidelines. The ban will last five years and is the result of a bribe to Implementing Agency officials of 17% of the total contract value in order to influence the Consortium’s technical score and for soliciting (unsuccessfully) Consortium Partners to participate in the corrupt payment.

May 25, 2012 – Lindsey Manufacturing

[DOJ] The US DOJ filed a motion in the U.S. Court of Appeals for the Ninth Circuit to voluntarily dismiss its appeal in the FCPA case against Lindsey Manufacturing Company. In his order of dismissal, U.S District Judge Howard Matz ruled that the Lindsey prosection had been tainted by a pervasive pattern of flagrant government misconduct at virtually every stage of the case. The motion means that the government will also end its efforts to forfeit about $24 million from the company.

May 21, 2012 – New York, Jean Rene Duperval – Haiti Telco

[DOJ] Jean-Rene Duperval, the director of international relations for state-owned Telecommunications firm HaÏti telco, who accepted bribes from several telecommunication firms based in Florida, was convicted by the US DOJ to 9 years in prison for laundering the bribes he accepted. The FCPA was not applicable as it is concerned only with active corruption. Duperval is the seventh individual sentenced to prison. Joel Esquenazi, the former president of Terra Telecommunications, was sentenced to 15 years in prison, the longest sanction thus far under the FCPA.

April 25, 2012 – Juan Pablo Vasquez – Latin Node

[DOJ] Juan Pablo Vasquez, a former executive at Latin Node received three years’ probation and a $7,500 fine after pleading guilty in January 2011 to a violation of the FCPA. The company was convicted and ordered to pay a $2M fine for bribing third parties up to $1.1M between 2004 and 2007 knowing that these bribes would benefit a state-owned telecommunications company in Honduras. The former president was sentenced last week to 23 months in prison and the former chief executive to four years.

April 25, 2012 – Garth Peterson, Morgan Stanley

[DOJ] The US DOJ announced that Garth Peterson – former managing director for Morgan Stanley’s real estate investment and fund advisory business in China – pleaded guilty to one-count of conspiring to circumvent Morgan Stanley’s internal controls, which the company is required to maintain under the FCPA. Peterson’s alleged misconduct, which occurred between October 2004 and December 2007, involved Peterson and a now former Chairman of Shanghai Yongye Enterprise (Group) Co. Ltd. (“Yongye”) – a Chinese state-owned entity with influence over the success of Morgan Stanley’s real estate business in Shanghai’s Luwan District – with whom Peterson had a pre-existing personal friendship and undisclosed business relationship.

April 20, 2012 – Manuel Caceres – Latin Node

[DOJ] Manuel Caceres, former vice president for business development of the telecommunications firm Latin Node was sentenced by the DOJ to 23 months in prison. He was sentenced for having bribed state-owned companies in Honduras (Hondutel), in Yemen (TeleYemen) including public officials in order to win an intercommunication agreement and to receive a favorable interconnection rate. Jorge Granados, the former president of Latin Node was convicted last September to 46 months in prison and Latin Node was ordered to pay $2M in April 2009 to the DOJ.

January 31, 2012 – Operation Navigator

[SFO] 4 individuals were convicted by Southwark Crown Court of conspiring to illegally obtain payments by supplying confidential information about a series of engineering projects based in Iran, Egypt, Russia, Singapore and Abu Dhabi between 2001 and 2009. The confidential information supplied to bidders was held by companies acting as procurement agents for the project. Defendants worked for these companies often on a short term basis. They had access to inside information which they passed on to targeted bidding companies who agreed to make illegal payments in exchange. Andrew Rybak (co-director of Strategic Project services) was sentenced to 5.5 years in prison, R. Saunders (agency worker in Snamprogetti) to 3.6 years, P.Hammond (Co-director of Strategic Project Services), to 3 years, and B.Smith, to 12 months. In addition, Rybak and Hammond were also disqualified from acting as company directors for a period of 10 years.

March 26, 2012 – Biomet

[DOJ/SEC] Biomet, a manufacturer of medical devices, was convicted by the US DOJ and the SEC to pay $22M for bribing four subsidiaries; publicly-employed doctors in Argentina, Brazil and China directly and through a distributor by paying them a certain percent of the value of their medical device purchases in order to secure lucrative business contracts with hospitals. Biomet concluded a deferred prosecution agreement with the DOJ and is required to retain a compliance monitor for 18 months.

March 14, 2012 – Bizjet Inc.

[DOJ] Bizjet was convicted by the US DOJ and ordered to pay $11.8M to resolve FCPA charges for bribing government officials in Latin America directly and through a shell company controlled and operated by a Bizjet sales manager in order to secure contracts for government agencies. Bizjet concluded a 3 year deferred prosecution agreement and agreed to cooperate fully with the DOJ by periodically reporting compliance efforts and by respecting its compliance program and internal controls in order to prevent further FCPA offenses.

February 22-23, 2012 – [TSKJ] Albert J. Stanley, Jeffrey Tesler, Wojciech J.Chodan

[DOJ] The DOJ sentenced A.J. Stanley, J. Tesler and W.J. Chodan for conspiring to violate the FCPA in the TSKJ (Technip, Snamprogetti, KBR, JGC) case. Albert Stanley, a former chairman and chief executive officer of Kellogg, Brown & Root (KBR) was sentenced on February 23, 2012 to 30 months in prison and to $10.8M in restitution to KBR. J. Tesler, a UK citizen and licensed solicitor hired by the joint-venture, was sentenced on February 23, 2012 to 21 months in prison, 2 years of supervised release and $25,000 fine. W.J. Chodan, a UK citizen and former salesman at KBR’s UK subsidiary was sentenced on February, 22, 2012 to one year of probation and ordered to pay a $20,000 fine. From 1994 to 2004, the Joint Venture companies and the three defendants bribed Nigerian government officials to obtain and retain engineering, procurement and construction contracts.

February 22, 2012 – Alstom

[World Bank] Alstom Hydro France and Alstom Network Schweiz AG (Switzerland) reached a Negotiated Resolution Agreement with the World Bank which includes a $9.5M restitution payment and a 3-year debarment of the two Alstom subsidiaries from World Bank development projects. In 2002, Alstom had made an improper payment of €110,000 to an entity controlled by a former Zambian senior government official for consultancy services in relation to the Zambia Power Rehabilitation Project. The debarment can be reduced to 21 months if the companies comply with all conditions of the agreement.

February 6, 2012 – Smith & Nephew

[DOJ/SEC] Smith & Nephew, a UK medical devices company, was convicted on February 6, 2012 and sentenced to pay $16.8M in penalties and $5.4M in disgorgement fees. Smith & Nephew was accused of bribing publicly-owned hospital employees through shell companies controlled by a Greek distributor. S&N sold its products at full list price to this Greek distributor and between 25 and 40 percent of the sales made by the distributor were paid to the shell companies, then paid in cash incentives to publicly-employed Greeks to induce the purchase of S&N products. S&N has entered into a deferred prosecution agreement with the DOJ and retained a compliance monitor for 18 months.

January 17, 2012 – Marubeni

[DOJ] Marubeni, the Japanese trading company implicated in the TSKJ case, agreed on January 17, 2012 to pay $54.6 million to the US DOJ for bribing Nigerian public officials as an agent of the KBR-led TSKJ joint venture. Marubeni was hired by the companies to help win contracts to build liquefied natural gas facilities on Bonny Island, Nigeria. Marubeni concluded a two year deferred prosecution agreement with the DOJ.

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