A company’s remediation and cooperation efforts recently helped it avoid prosecution for violations of the Foreign Corrupt Practices Act.
According to a Department of Justice letter, a DOJ investigation found evidence that for more than a year the company’s former U.S. subsidiary, including employees of a maquiladora owned and operated by that subsidiary, paid bribes to one or more Mexican government officials to secure a permit and prepared fraudulent manifests to disguise those bribes.
However, the DOJ said it has declined prosecution of this matter based on a number of factors, including the company’s timely and voluntary self-disclosure of the misconduct; full, proactive, and continuing cooperation; and timely and appropriate remediation, including substantially improving its compliance program and internal controls. The DOJ also cited the company’s agreement to disgorge the costs it avoided as a result of the bribery (less the duties paid to Mexican regulators).
For more information on the FCPA and how to ensure your company’s compliance, please contact attorney Kristine Pirnia at (202) 730-4964 or via email.
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