FCPA

December 22, 2017

Keppel Offshore & Marine Ltd., 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., agreed to pay a combined total penalty of more than $422 million to resolve criminal charges of violating the Foreign Corrupt Practices Act and related charges from authorities in Brazil and Singapore. Specifically, Keppel participated in a decade-long scheme to pay millions of dollars in bribes to officials in Brazil. DOJ

November 29, 2017

SBM Offshore N.V., a Netherlands-based company specializing in the manufacture and design of offshore oil drilling equipment, and its wholly-owned U.S. subsidiary SBM Offshore USA Inc., agreed to resolve criminal charges and pay a criminal penalty of $238 million for violating the Foreign Corrupt Practices Act (FCPA) in connection with schemes involving the bribery of foreign officials in Brazil, Angola, Equatorial Guinea, Kazakhstan and Iraq.  According to company admissions, SBM paid more than $180 million in commissions to intermediaries, knowing that a portion of those commissions would be used to bribe foreign officials and that SBM gained at least $2.8 billion from projects it obtained from these illicit payments.  DOJ

September 28, 2017

The South Korean subsidiary of Alere Inc. has agreed to pay more than $13 million to settle charges that it committed accounting fraud through its subsidiaries to meet revenue targets and made improper payments to foreign officials to increase sales in certain countries. The Securities and Exchange Commission issued an order finding that Alere, which produces and sells diagnostic testing equipment, improperly inflated revenues by prematurely recording sales for products that were still being stored at warehouses or otherwise not yet delivered to the customers.  According to the SEC’s order, Alere also engaged in improper revenue recognition practices at several other subsidiaries. SEC

September 21, 2017

Sweden-based telecommunications provider Telia Company AB has agreed to pay $965 million in a global settlement with the Securities and Exchange Commission, U.S. Department of Justice, and Dutch and Swedish law enforcement to resolve charges related to violations of the Foreign Corrupt Practices Act (FCPA) to win business in Uzbekistan. According to the SEC’s order, Telia entered the Uzbek telecommunications market by offering and paying at least $330 million in bribes to a shell company under the guise of payments for lobbying and consulting services that never actually occurred.  The shell company was controlled by an Uzbek government official who was a family member of the President of Uzbekistan and in a position to exert significant influence over other Uzbek officials, causing them to take official actions to benefit Telia’s business in Uzbekistan. SEC

September 21, 2017

Stockholm-based Telia Company AB and its Uzbek subsidiary Coscom LLC agreed to pay a combined total penalty of more than $965 million to resolve charges of violating the Foreign Corrupt Practices Act (FCPA) arising out of a scheme to pay bribes in Uzbekistan.  According to the government, it is one of the largest criminal corporate bribery and corruption resolutions ever. DOJ