Background

The Department of Justice has declined to prosecute a U.S. company for bribing foreign officials due to its cooperation and remediation efforts but is requiring the company to disgorge $7.82 million in profits and forfeit another $3.42 million in corrupt proceeds.

A DOJ investigation found that the company violated the Foreign Corrupt Practices Act by making corrupt payments to high-level officials at a state-owned and –controlled entity in the Republic of Georgia in return for their assistance in a purchase of income-producing assets. However, consistent with a pilot program designed to motivate companies to voluntarily self-disclose FCPA-related misconduct, the DOJ has decided to close its investigation without further action based on a number of steps the company took, including the following.

- timely, voluntary self-disclosure of the matter

- thorough, comprehensive, and proactive investigation

- full cooperation and agreement to continue to cooperate in any ongoing investigations of individuals

- enhancement of compliance program and internal accounting controls

- full remediation, including terminating and/or taking disciplinary action against the employees involved in the misconduct

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