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$54.6 Million Fine Brings Total Penalties for Nigerian Bribery Case to $1.7 Billion

Thursday, January 19, 2012
Sandler, Travis & Rosenberg Trade Report

The Department of Justice announced Jan. 17 that a Japanese trading company has agreed to pay a $54.6 million criminal penalty to resolve allegations that it violated the Foreign Corrupt Practices Act by participating in a decade-long scheme to bribe Nigerian government officials to obtain engineering, procurement and construction contracts. Under the terms of a deferred prosecution agreement, DOJ will dismiss the criminal charges after two years provided that the company retains a corporate compliance consultant during that period to review the design and implementation of its compliance program, enhances its compliance program to ensure that it satisfies certain standards, and cooperates with DOJ in ongoing investigations. The department states that it has now held accountable all five of the corporations that participated in the scheme to bribe Nigerian government officials in connection with the so-called Bonny Island project and obtained more than $1.7 billion in penalties and forfeiture orders.

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