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

Copyright © 2021 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services 


Cookie Consent

We use cookies on our website. By continuing to use our website, you agree to the Privacy Policy and Terms of Use.