Background

The Department of Justice has decided to close without prosecution an investigation into charges that an insurance company violated the Foreign Corrupt Practices Act. The DOJ alleged that the company paid approximately $36,000 in bribes to the commerce minister of Barbados in exchange for insurance contracts resulting in approximately $686,827.50 in total premiums and approximately $93,940.19 in net profits.

The DOJ states that despite the high-level involvement of corporate officers in the misconduct it is closing this investigation based on a number of factors, including the company’s timely, voluntary self-disclosure of the violations, thorough and comprehensive investigation, cooperation with the DOJ, agreement to disgorge all profits made from the illegal conduct, steps to enhance its compliance program and internal accounting controls,; and remediation, including terminating all of the executives and employees involved in the misconduct.

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