The Department of Justice reports that a Venezuela-based subsidiary of a Spanish company will pay more than $85.2 million as part of a deferred prosecution agreement resolving an investigation into a scheme to bribe government officials in Venezuela in violation of the Foreign Corrupt Practices Act. The two companies will also enhance their compliance programs where necessary and appropriate and report to the U.S. government regarding remediation and implementation of those programs.
According to a DOJ press release, the subsidiary bribed Venezuelan government officials to participate in a government auction through which it exchanged Venezuelan bolivars for U.S. dollars. The company concealed the illicit payments by purchasing equipment at inflated prices from two suppliers who funneled the bribes through U.S. correspondent bank accounts on the company’s behalf.
The DOJ notes that the subsidiary received credit for its cooperation with the department’s investigation as well as its timely remedial measures, which included (1) building and empowering an independent compliance function and ensuring that it reviews all transactions with non-standard pricing, (2) appointing a chief compliance officer with direct access to the audit committee of the board of directors, (3) investing in additional compliance resources throughout its global operations, (4) reviewing, enhancing, and testing its broader internal controls for pricing and other transactions with the assistance of a forensic accounting firm, (5) strengthening its processes for vetting, engaging, and monitoring third parties, and (6) establishing risk assessment and audit processes to regularly review and update the compliance program and otherwise mitigate business risks.
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