FCPA

September 6, 2018

A real estate broker for Colliers International Group, Inc. has agreed to pay $225,000 to settle FCPA charges of attempting to bribe a foreign official over the sale of a commercial building in Vietnam. The broker, Joohyun Bahn, had paid the bribe to a middleman, bypassed internal accounting controls, created fake documents and messages, and lied to executives about the supposedly impending sale, which caused the company to falsely record revenue. Unfortunately for Bahn, the sale never went through because the middleman had kept the bribe for himself. SEC

September 4, 2018

Pharmaceutical company Sanofi has agreed to pay more than $25 million to resolve charges under the FCPA that it made corrupt payments to win business in Kazakhstan and the Middle East. Sanofi was alleged to have made payments to various government officials and healthcare providers to induce them to purchase or prescribe Sanofi's products.  SEC

August 27, 2018

Legg Mason Inc. has agreed to pay $34 million to settle a charge that it bribed Libyan government officials to secure investments from state-owned financial institutions. As a result of the bribes, which violated the Foreign Corrupt Practices Act (FCPA), Legg Mason was allegedly awarded investments worth $1 billion, and earned revenues totaling $31.6 million. The SEC fine comes at the heels of a $33 million fine that Legg Mason had previously agreed to pay to DOJ in a similar settlement. SEC

July 5, 2018

Credit Suisse will pay a total of $77 million – $47 million as a criminal penalty and $30 million in disgorgement and interest – to resolve charges that it obtained investment banking business in the Asia-Pacific region by corruptly influencing foreign officials in violation of Foreign Corrupt Practices Act (FCPA).  The government charged that Credit Suisse attempted to secure banking business by offering of employment to family and friends of influential Chinese government officials.  SEC; DOJ; USAO EDNY

July 2, 2018

Distilled spirits company Beam Suntory, Inc. agreed to pay more than $8 million to resolve charges that its Indian subsidiary made improper payments in violation of the FCPA.  Beam was alleged to have used third parties to make unlawful payments to government employees to induce them to process license and label registrations and purchase Beam's products.  The third parties submitted false and inflated invoices to Beam, which paid them through its Indian subsidiary.  SEC

June 27, 2018

Egbert Yvan Ferdinand Koolman, an Aruban telecommunications purchasing official was sentenced to 36 months in prison related to money laundering charges in connection with a scheme to arrange and receive payment to influence the awarding of contract with an Aruban-owned company. Koolman along with others admitted to transmitting funds from Florida and other areas of the United States to Aruba and Panama in a wire fraud scheme that violated the Foreign Corrupt Practices Act (“FCPA”). DOJ

June 4, 2018

France-based global financial services institution Société Générale S.A. and a wholly-owned subsidiary agreed to collectively pay penalties and disgorgement in excess of $1 billion to resolve U.S. and French charges related to the bribery of Libyan officials between 2004 and 2009 in exchange for various investments worth more than $3 billion, as well as the manipulation of LIBOR through the issuance of false financial data. USAO EDNY

June 4, 2018

Maryland-based investment management firm Legg Mason, Inc. will pay $64.2 million to end an FCPA investigation into Legg Mason’s participation in a scheme to bribe Gaddafi-era Libyan officials; Legg Mason’s involvement, through subsidiary Permal Group Ltd., was in partnership with Société Générale S.A., which also settled today. USAO EDNY