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Japanese Company Fined $88 Million for Bribing Indonesian Government Officials

Friday, March 21, 2014
Sandler, Travis & Rosenberg Trade Report

The Department of Justice announced March 19 that a Japanese trading company involved in the handling of products and provision of services in a broad range of sectors around the world has agreed to pay an $88 million criminal fine for its participation in a seven-year scheme to pay and conceal bribes to high-ranking government officials in Indonesia to secure a $118 million power project. As part of a plea agreement, the company has also agreed to maintain and implement an enhanced global anti-corruption compliance program and to cooperate with the DOJ’s ongoing investigation. 

A DOJ press release states that the Japanese company, which “worked in concert with a Connecticut company” and others to advance the bribery scheme, pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act and seven counts of violating the FCPA. The DOJ considered a number of factors in determining a penalty , the press release adds, including the company’s decision not to cooperate with the DOJ’s investigation when given the opportunity to do so, its lack of an effective compliance and ethics program at the time of the offense, its failure to properly remediate, and the lack of its voluntary disclosure of the conduct.

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