The Department of Justice reports that a U.S. company has agreed to resolve criminal charges in connection with a scheme that involved the bribery of an official at a subsidiary of Russia’s State Atomic Energy Corporation. A DOJ press release states that for about ten years this company conspired with others to corruptly pay more than $1.7 million to this official to help the company secure improper business advantages and obtain and retain business. To effectuate and conceal the payments, company executives and others caused fake invoices to be prepared describing services that were never provided. The company then wired payments for those purported services to shell companies in Latvia, Cyprus, and Switzerland.

According to an agency press release, the DOJ and the company agreed in a deferred prosecution agreement that the appropriate criminal penalty is $2 million in light of the company’s financial inability to pay the penalty calculated under the U.S. Sentencing Guidelines. The company also received full credit for its substantial cooperation with the DOJ’s investigation and for engaging in remedial measures, including terminating the employment of all employees engaged in the misconduct.

Also as part of the DPA the company has committed to (a) cooperate fully with the DOJ’s ongoing investigation and (b) continue to implement a compliance and ethics program designed to prevent and detect violations of the FCPA and other anti-corruption laws throughout its operations.

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