Background

The Securities and Exchange Commission announced Aug. 27 that a company will pay more than $34 million to resolve charges that it violated the Foreign Corrupt Practices Act in a scheme to bribe Libyan government officials. Specifically, the company agreed to disgorge approximately $27.6 million in profits plus $6.9 million in prejudgment interest. The company previously entered into a non-prosecution agreement with the Department of Justice concerning the same scheme in which it agreed to pay another $33 million.

The SEC alleges that between 2004 and 2010 a former asset management subsidiary of the company partnered with a French financial services company to solicit investment business from Libyan state-owned financial institutions. These entities engaged in a scheme to pay bribes to Libyan government officials through a Libyan middleman in order to secure investments. As a result of this scheme, the company was awarded business tied to $1 billion of investments that earned net revenues of approximately $31.6 million.

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