Difference between revisions of "Foreign bribery and FCPA violations"

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|[https://www.justice.gov/opa/pr/teva-pharmaceutical-industries-ltd-agrees-pay-more-283-million-resolve-foreign-corrupt $519 Million]
|[https://www.justice.gov/opa/pr/teva-pharmaceutical-industries-ltd-agrees-pay-more-283-million-resolve-foreign-corrupt $519 Million]
|Teva Pharmaceutical Industries Ltd. (Teva) violated the FCPA by bribing government officials in Russia, Ukraine, and Mexico. In Russia, bribes were paid to influence the increase in sales of Teva’s multiple sclerosis drug Copaxone by the Russian Ministry of Health. In the Ukraine, bribes were paid to influence the government’s approval of Teva drug registrations. In Mexico, bribes were paid to doctors employed by the Mexican government to prescribe Copaxone to patients.
|Teva Pharmaceutical Industries Ltd. (Teva) violated the FCPA by bribing government officials in Russia, Ukraine, and Mexico. In Russia, bribes were paid to influence the increase in sales of Teva’s multiple sclerosis drug Copaxone by the Russian Ministry of Health. In the Ukraine, bribes were paid to influence the government’s approval of Teva drug registrations. In Mexico, bribes were paid to doctors employed by the Mexican government to prescribe Copaxone to patients.
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|Och-Ziff Capital Management Group, LLC
|[https://www.justice.gov/opa/pr/och-ziff-capital-management-admits-role-africa-bribery-conspiracies-and-agrees-pay-213 $412 Million]
|Och-Ziff, a New York-based investment and hedge fund manager, violated the FCPA by repeatedly facilitating corrupt transactions that they knew were bribes being paid to government officials in the Democratic Republic of the Congo, Libya, Chad, and Niger to secure investment opportunities. Och-Ziff was charged with two counts of conspiracy to violate the anti-bribery provisions of the FCPA, one count of fasifying records, and one count of inadequate internal controls.
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|BAE
|[https://www.justice.gov/opa/pr/bae-systems-plc-pleads-guilty-and-ordered-pay-400-million-criminal-fine $400 Million]
|BAE Systems PLC (BAES) violated the FCPA when it “knowingly and willfully failed to create sufficient compliance mechanisms to prevent and detect violations of the anti-bribery provisions of the FCPA” after stating it would create and implement such policies to ensure FCPA compliance to various U.S. government agencies. BAES regularly hired “marketing advisors” to assist in securing sales of defense items and concealed those relationships from the U.S. government. It made payments to these marketing advisors via shell companies that were not subjected to the level of scrutiny that BAES had told the U.S. government, leading to a violation of making false statements about its FCPA compliance program.
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|Total SA
|[https://www.justice.gov/opa/pr/french-oil-and-gas-company-total-sa-charged-united-states-and-france-connection-international $398 Million]
|French oil and gas company Total violated the FCPA when it made approximately $60 million in bribe payments over a nine year period to an Iranian government official in exchange for lucrative oil rights in the Sirri A and E and South Pars oil and gas fields. The illegal payments were cited as business development expenses and made to intermediaries hired as consultants, as designated by the Iranian government official.
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|Alcoa
|[https://www.justice.gov/opa/pr/alcoa-world-alumina-agrees-plead-guilty-foreign-bribery-and-pay-223-million-fines-and $384 Million]
|Alcoa’s Australian subsidiary repeatedly paid bribes to government officials in Bahrain via a London-based consultant hired to assist in negotiations for long-term alumina supply agreements with Alba, one of the largest aluminum smelters in the world and controlled by Bahrain’s government. Alcoa’s mining operations in Australia were the source of the alumina supplied to Alba. The consultant generated the funds needed to pay bribes from commissions and price markups. Bribes were paid to Bahraini government officials, members of Alba’s board of directors, and Alba senior management. Alcoa was found to have failed to implement sufficient internal controls to prevent and detect such bribes.
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|ENI S.p.A, Snamprogetti
|[https://www.justice.gov/opa/pr/snamprogetti-netherlands-bv-resolves-foreign-corrupt-practices-act-investigation-and-agrees $365 Million]
|Snamprogetti and ENI violated the FCPA’s anti-bribery provisions when they engaged in a decade-long bribery scheme with companies KBR, Technip, and JGC of Japan to bribe Nigerian officials in exchange for EPC contracts by Nigeria LNG Ltd. The four company joint venture was called TSKJ and won contracts to build liquefied natural gas (LNG) facilities on Bonny Island worth more than $6 billion. TSKJ hired two agents to pay the bribes to Nigerian government officials through various sources on behalf of their joint-venture.
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|Technip
|[https://www.justice.gov/opa/pr/technip-sa-resolves-foreign-corrupt-practices-act-investigation-and-agrees-pay-240-million $338 Million]
|Paris-based Technip, a global engineering, construction and services company participated in a decade-long bribery scheme to obtain engineering, procurement, and construction (EPC) contracts in Nigeria with their joint venture partners KBR, Snamprogetti, and JGC of Japan. The contracts to build LNG facilities on Bonny Island were valued at more than $6 billion.
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