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« Job: Compliance Counsel (Panasonic Avionics Corporation - Singapore) | Main | Teva pays second biggest FCPA disgorgement »
Tuesday
Jan032017

The 2016 FCPA Enforcement Index

Last year 27 companies paid about $2.48 billion to resolve FCPA cases. It was the biggest enforcement year in FCPA history. Both the number of enforcement actions and the overall amounts paid to resolve them were records.

Four blockbuster FCPA settlements in 2016 -- Teva Pharmaceutical at $519 million, Odebrecht / Braskem at $419.8 million, Och-Ziff at $412 million, and VimpelCom at $397.6 million -- landed on our list of the ten biggest FCPA cases of all time.

For comparison:

  • In 2015, 11 companies paid $133 million to resolve FCPA cases.
  • In 2014, 10 companies paid $1.56 billion.
  • In 2013, 12 companies paid $731.1 million.
  • In 2012, 12 companies paid $259.4 million.
  • In 2011, 15 companies paid $508.6 million.
  • In 2010, 23 companies paid $1.8 billion.
  • In 2009, 11 companies paid $644 million, and
  • In 2008, 11 companies paid $890 million.

In 2016, 15 individuals settled civil FCPA charges brought by the SEC.

Two corporate enforcement actions in 2016 (HMT LLC and NCH Corporation) were declinations with disgorgement -- a new category of enforcement action created as part of the DOJ's Pilot Program.

There were twelve other declinations reported during the year. Three of those were issued under the DOJ's Pilot Program to Nortek, Akamai, and Johnson Controls, with the companies also disgorging profits through SEC enforcement actions.

Ten individuals pleaded guilty to FCPA criminal charges during 2016 and haven't been sentenced yet. Two others were indicted during the year but hadn't entered pleas. Two individuals were sentenced for criminal FCPA offenses in 2016 -- one to prison and one to probation.

In 2016 there were enforcement actions against seven former foreign officials who took bribes from FCPA offenders. The DOJ charged them with money laundering-related offenses. (The FCPA reaches bribe payers but not bribe takers.)

*     *     *

DOJ / SEC Enforcement Resolutions 

Corporate Actions

SAP SE (February 1) paid nearly $3.9 million to settle charges that it violated the Foreign Corrupt Practices Act by paying bribes to win business in Panama. SAP’s faulty internal controls allowed a former vice president of global and strategic accounts, Vicente Garcia, to pay $145,000 in bribes to a senior Panama official and offer bribes to two others in exchange for sales contracts. Garcia, 65, of Miami, was jailed 22 months in December 2015.

SciClone Pharmaceuticals (February 4) paid $12.8 million to settle China FCPA offenses brought by the SEC. China employees pumped up sales for five years by making improper payments to professionals employed at state health institutions, the SEC said. They gave money, gifts, travel, golf games, and lavish hospitality to China customers and decision makers.

PTC Inc. (February 16) paid $28 million to resolve FCPA offenses. Two China units of the Massachusetts software company entered into a non-prosecution agreement and paid a $14.5 million criminal penalty to resolve a DOJ investigation into payments for recreational travel by Chinese government officials that violated the Foreign Corrupt Practices Act. PTC Inc. also reached a civil settlement with the SEC by disgorging $11.8 million and paying nearly $1.8 million in prejudgment interest.

VimpelCom Limited (February 18) and its wholly owned Uzbek subsidiary, Unitel LLC, paid $397.6 million to the DOJ and SEC for bribing a government official in Uzbekistan between 2006 and 2012. VimpelCom paid a $230.1 million criminal penalty to the DOJ and $167.5 million in disgorgement and pre-judgment interest to the SEC. The DOJ charged VimpelCom with conspiracy to violate the antibribery and books and records provisions of the FCPA, with a separate count of violating the FCPA's internal controls provisions.

Qualcomm Incorporated (March 1) paid $7.5 million to settle SEC charges that it violated the Foreign Corrupt Practices Act by hiring relatives of Chinese government officials. The officials were in positions to decide whether to select Qualcomm’s mobile technology products amid increasing competition in the international telecommunications market, the SEC said.

Olympus Corporation of the Americas (March 1). The company's Latin America unit paid the DOJ $22.8 million to resolve criminal allegations that it violated the FCPA. Olympus Latin America, Inc. also entered into a three-year deferred prosecution agreement with enhanced compliance obligations. Under a three-year deferred prosecution agreement, a compliance monitor will "assess and monitor" Olympus Corporation of the Americas's FCPA compliance program.

Nordion (Canada) Inc. (March 4) paid a $375,000 penalty to settle SEC charges that it lacked internal accounting controls and basic FCPA due diligence. A former employee, Mikhail Gourevitch (see below), bribed Russian government officials.

Novartis AG (March 23) paid $25 million to the SEC to resolve FCPA offenses. The SEC alleged that two China-based subsidiaries bribed doctors and others to prescribe its drugs. Novartis improperly recorded the payments as travel and entertainment, conferences, lecture fees, marketing events, educational seminars, and medical studies. It agreed to disgorge $21.5 million and pay $1.5 million in prejudgment interest, and a $2 million penalty.

Las Vegas Sands Corp. (April 7) paid the SEC a $9 million penalty to settle charges that it violated the Foreign Corrupt Practices Act by failing to properly authorize or document millions of dollars in payments to a consultant hired to help it do business in China and Macau.

Akamai Technologies (June 7) agreed pursuant to an SEC non-prosecution agreement to pay about $672,000, consisting of $652,500 in disgorgement and $19,400 in interest to resolve FCPA offenses for bribes foreign subsidiaries paid to Chinese officials.

Nortek Inc. (June 7) agreed pursuant to an SEC non-prosecution agreement to pay about $321,000, consisting of $291,000 in disgorgement and $30,000 in interest to resolve FCPA offenses for bribes foreign subsidiaries paid to Chinese officials.

Analogic Corporation (June 21) and a foreign subsidiary paid $14.8 million to resolve FCPA offenses related to $20 million in improper payments in Russia and other countries. In a settlement with the SEC, Analogic paid $7.7 million in disgorgement and $3.8 million in prejudgment interest. Analogic’s Danish subsidiary, BK Medical ApS, entered into a non-prosecution agreement with the DOJ and agreed to pay a $3.4 million criminal penalty.

Johnson Controls Inc. (July 11) paid $14 million to settle SEC charges that it violated the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act. The SEC said a China subsidiary used sham vendors to pay bribes of about $4.9 million to employees of Chinese government-owned shipyards, ship-owners and others.

LATAM Airlines Group S.A. (July 25), a commercial airline company based in Chile, agreed to pay more than $22 million to the DOJ and SEC to resolve FCPA offenses for bribing union officials in Argentina. The company paid a $12.75 million criminal penalty to the DOJ. The DOJ charged LATAM in federal court in Miami with one count of violating the FCPA books and records provisions and one count of violating the internal controls provisions of the FCPA. LATAM paid the SEC $9.44 million -- $6.74 million in disgorgement and $2.7 million in prejudgment interest.

Key Energy Services, Inc. (August 12) agreed to disgorge $5 million to the SEC to settle Foreign Corrupt Practices Act offenses for bribes from its Mexican subsidiary to an employee at state-owned Pemex.

AstraZeneca PLC (August 31) paid the SEC $5.5 million to resolve charges that it violated the books and records and internal controls provisions of the Foreign Corrupt Practices Act when wholly-owned subsidiaries in China and Russia made illegal payments to boost drug sales. AstraZeneca paid $4.325 million in disgorgement, $822,000 in prejudgment interest, and a $375,000 civil penalty.

Nu Skin Enterprises, Inc. (September 20) paid almost $766,000 to settle charges that it violated the internal controls and books-and-records provisions of the FCPA. The FCPA violations arose from a $150,000 payment Nu Skin's China subsidiary made to a charity so that a high-ranking Chinese Communist party official would intervene in an on-going provincial agency investigation.

Anheuser-Busch InBev (September 28) paid $6 million to settle charges that it violated the FCPA and impeded a whistleblower who reported the misconduct. The company used third-party sales promoters to make improper payments to government officials in India. And it entered into a separation agreement that deterred an employee of its India unit from continuing to voluntarily communicate with the SEC about potential FCPA violations.

Och-Ziff Capital Management Group (September 29) paid the DOJ and SEC $412 million for criminal and civil FCPA violations. A three-year deferred prosecution agreement charged Och-Ziff with two counts of conspiracy to violate the anti-bribery provisions of the FCPA, one count of falsifying its books and records, and one count of failing to implement adequate internal controls. Subsidiary OZ Africa Management GP LLC pleaded guilty in federal court to a one-count criminal information that charged it with a conspiracy to violate the anti-bribery provisions of the FCPA.

HMT LLC (September 29) received a DOJ Pilot Program declination for FCPA offenses in Venezuela and China that required disgorgement of $2.7 million.

NCH Corporation (September 29) received a DOJ Pilot Program declination for FCPA offenses in China that required disgorgement of $335,000.

GlaxoSmithKline plc (September 30) paid the SEC a $20 million penalty to resolve FCPA offenses in China. GSK's China-based subsidiaries spent millions of dollars on pay-to-prescribe schemes for several years to pump up sales. The FCPA offenses involved gifts, improper travel and entertainment, shopping excursions, family and home visits, and cash. GSK recorded the illegal payments and gifts as legitimate expenses.

Embraer SA (October 24) paid more than $205 million to the DOJ and SEC to resolve FCPA violations  in the Dominican Republic, Saudi Arabia, and Mozambique. The SEC also accused Embraer of an accounting scheme in India to hide payments there. Embraer is paying a $107 million criminal penalty to the Justice Department as part of a three-year deferred prosecution agreement. It also paid more than $98 million in disgorgement and interest to the SEC.

JPMorgan Chase & Co. (November 17) and a Hong Kong subsidiary paid $264.4 million to the DOJ, SEC, and Federal Reserve to resolve FCPA offenses for awarding prestigious jobs to relatives and friends of Chinese government officials to win banking deals. The Hong Kong unit paid a $72 million criminal penalty as part of a non-prosecution agreement with the DOJ. JPMorgan Chase disgorged $130.5 million, including prejudgment interest, to the SEC. The Federal Reserve System’s Board of Governors also issued a consent cease-and-desist order that assessed a $61.9 million civil penalty against JPMorgan Chase.

Odebrecht S.A. and Braskem S.A. (December 21) each pleaded guilty to one count of conspiring to violate the FCPA anti-bribery provisions. Together they agreed to pay at least $419.8 million. Odebrecht's criminal penalty to the DOJ will be at least $260 million and its subsidiary Braskem agreed to pay the DOJ and SEC $159.8 million, consisting of a criminal penalty to the DOJ of $94.8 million and disgorgement and interest to the SEC $65 million.

Teva Pharmaceuticals Industries Ltd. (December 22) agreed to pay the DOJ and SEC $519 million for FCPA offenses in Ukraine, Mexico, and Russia. Under a three-year deferred prosecution agreement, Teva will pay a criminal fine of $283 milion. In the SEC enforcement action, the company will disgorge $236 million. A Russia subsidiary pleaded guilty to a one-count criminal information that charged a conspiracy to violate the anti-bribery provisions of the FCPA.

General Cable Corporation (December 29) agreed to pay the DOJ and SEC $75.75 million to resolve FCPA violations in Angola, Bangladesh, China, Egypt, Indonesia, and Thailand. The company entered into a non-prosecution agreement with the DOJ on December 22 and agreed to pay a $20.4 million criminal penalty. With the SEC, General Cable agreed to pay more than $55.3 million in disgorgement and prejudgment interest.

Individual Actions (SEC)

Ignacio Cueto Plaza (February 4), the CEO of South America-based LAN Airlines, paid $75,000 to resolve SEC charges that he violated the Foreign Corrupt Practices Act when he authorized more than $1 million in improper payments to a sham consultant during a dispute between the airline and its unionized employees in Argentina. Cueto, 51, is a Chilean citizen.

Yu Kai Yuan (February 17), a former employee at PTC's China subsidiaries, resolved FCPA offenses through the SEC's first deferred prosecution agreement with an individual in an FCPA case. The SEC deferred FCPA civil charges for three years "as a result of significant cooperation" Yuan provided during the investigation. Yuan, 47, a Chinese citizen, lives in Shanghai. From 1996 until 2011, he worked as a sales executive at PTC units Parametric Technology (Hong Kong) Ltd. and  Parametric Technology (Shanghai) Software Co., Ltd.

Mikhail Gourevitch (March 4), a former engineer for Nordion, paid $178,950 to settle SEC charges that he violated the FCPA and also took kickbacks. He paid $100,000 in disgorgement, $12,950 in prejudgment interest, and a $66,000 penalty. He arranged bribes to Russian officials through a third-party agent for approval to sell a Nordion liver cancer treatment called TheraSphere. Gourevitch, a dual citizen of Canada and Israel, lived in Canada when he worked for Nordion and now lives in Israel.

Iuri Rodolfo Bethancourt (April 8) of Direct Access Partners settled SEC charges related to bribes paid to a former official of a Venezuelan state-owned bank. A court judgment permanently enjoined Bethancourt from violating securities laws.

Benito Chinea (April 8) of Direct Access Partners settled SEC charges related to bribes paid to a former official of a Venezuelan state-owned bank. A court judgment permanently enjoined Chinea from violating securities laws. He was ordered to pay $42.5 million in disgorgement and prejudgment interest. The disgorgement and prejudgment interest were deemed satisfied by forfeiture orders entered in parallel criminal cases.

Tomas Alberto Clarke Bethancourt (April 8) of Direct Access Partners settled SEC charges related to bribes paid to a former official of a Venezuelan state-owned bank. A court judgment permanently enjoined Clarke from violating securities laws. He was ordered to pay $42.5 million in disgorgement and prejudgment interest. The disgorgement and prejudgment interest were deemed satisfied by forfeiture orders entered in parallel criminal cases.

Joseph DeMeneses (April 8) of Direct Access Partners settled SEC charges related to bribes paid to a former official of a Venezuelan state-owned bank. A court judgment permanently enjoined DeMeneses from violating securities laws. He was ordered to pay $42.5 million in disgorgement and prejudgment interest. The disgorgement and prejudgment interest were deemed satisfied by forfeiture orders entered in parallel criminal cases.

Jose Alejandro Hurtado (April 8) of Direct Access Partners settled SEC charges related to bribes paid to a former official of a Venezuelan state-owned bank. A court judgment permanently enjoined Hurtado from violating securities laws. He was ordered to pay $42.5 million in disgorgement and prejudgment interest. The disgorgement and prejudgment interest were deemed satisfied by forfeiture orders entered in parallel criminal cases.

Ernesto Lujan (April 8) of Direct Access Partners settled SEC charges related to bribes paid to a former official of a Venezuelan state-owned bank. A court judgment permanently enjoined Lujan from violating securities laws. He was ordered to pay $42.5 million in disgorgement and prejudgment interest. The disgorgement and prejudgment interest were deemed satisfied by forfeiture orders entered in parallel criminal cases.

Haydee Leticia Pabon (April 8) of Direct Access Partners settled SEC charges related to bribes paid to a former official of a Venezuelan state-owned bank. A court judgment permanently enjoined Pabon from violating securities laws.

Lars Frost (June 21), BK Medical’s CFO from 2008 to 2011, paid the SEC a civil penalty of $20,000 to settle FCPA offenses.

Jun Ping Zhang (September 13), 50, the former chief of Harris Corporation's Carefx subsidiary in China, agreed to pay the SEC a civil penalty of $46,000 for helping bribe China officials with up to a million dollars in gifts, and covering up the scheme in Harris's books and records.

Daniel Och (September 29), the CEO of Och-Ziff, paid nearly $2.2 million to settle SEC charges that he caused FCPA violations.

Joel Frank (September 29), the Och-Ziff CFO, agreed to settle SEC charges that he caused violations in Och-Ziff transactions in Libya and the Democratic Republic of the Congo. A "penalty will be assessed against him at a future date," the SEC said.

Karl Zimmer (December 29), 40, a former senior vice president at General Cable, settled SEC allegations that he caused FCPA violations and knowingly circumvented accounting controls by approving excessive commission payments to an agent in Angola. Zimmer didn't admit or deny the SEC findings. He agreed to pay a $20,000 penalty.

Guilty Pleas

Abraham Jose Shiera Bastidas (March 22), 52, of Coral Gables, Florida, pleaded guilty in federal court to one count of conspiracy to violate the Foreign Corrupt Practices Act and commit wire fraud and one count of violating the FCPA. He bribed officials to win contracts from Venezuela’s state-owned energy company, Petroleos de Venezuela S.A. (PDVSA). Sentencing is scheduled for July 8.

Moises Abraham Millan Escobar (March 22), 32, of Katy, Texas, a one-time employee of Shiera, had his guilty plea  unsealed. He entered the plea in January. He pleaded guilty to one count of conspiracy to violate the FCPA for bribing PDVSA officials.  

Dmitrij Harder (April 20), a Russian national living in Huntingdon Valley, Pennsylvania, pleaded guilty to two counts of violating the FCPA by bribing an official at the European Bank for Reconstruction and Development. Harder owned Chestnut Consulting Group Inc. Sentencing is set for July 21. He faces up to ten years in prison.

Roberto Enrique Rincon Fernandez (June 16) of The Woodlands, Texas, pleaded guilty in federal court in Houston to bribing officials at Venezuela’s state-owned energy company PDVSA to win work and speed up contract payments. He pleaded guilty to one count of conspiracy to violate the FCPA, one count of violating the FCPA, and one count of making false statements on his 2010 federal income tax return. Sentencing is set for September 30.

Moises Abraham Millan Escobar (June 16), of Katy, Texas, had his guilty plea unsealed. He entered the plea in January. He pleaded guilty to one count of conspiracy to violate the FCPA by bribing PDVSA officials.

Victor Hugo Valdez Pinon (October 26), 54, a citizen of Mexico, pleaded guilty to conspiracy to violate the FCPA and conspiracy to commit wire fraud for bribes to Mexican officials. He's scheduled to be sentenced on February 23.

Douglas Ray (October 28), 55, of Magnolia, Texas, pleaded guilty to conspiracy to violate the FCPA and conspiracy to commit wire fraud for bribes to Mexican officials. He's scheduled to be sentenced on February 23.

Kamta Ramnarine (November 2), 69, of Brownsville, Texas, pleaded guilty on November 2 to conspiracy to violate the FCPA for bribes to Mexican officials. He's scheduled to be sentenced on January 30.

Daniel Perez (November 2), 69, of Brownsville, Texas, pleaded guilty on November 2 to conspiracy to violate the FCPA for bribes to Mexican officials. He's scheduled to be sentenced on January 30.

Samuel Mebiame (December 9), the son of a former Prime Minister of Gabon, pleaded guilty to a one-count FCPA conspiracy for bribing African officials on behalf of a mining company owned by an Och-Ziff joint venture. Sentencing is set for April 6.

Indicted

Ng Lap Seng (November 22) was charged in a superseding indictment with paying at least $500,000 in bribes the former president of the United Nations General Assembly, John Ashe. Ng, from Macau, was originally charged in October 2015 with domestic bribery, currency smuggling, and tax-related crimes.

Jeff Yin (November 22), Ng Lap Seng's assistant, was charged in a superseding indictment with FCPA violations. He had also been charged in the original indictment in October 2015.

Sentenced

James McClung (July 7), 60, of Dubai, a former senior vice president of Louis Berger International, was sentenced to a year and a day in prison for bribing officials for more than a decade to win contracts in India, Indonesia, Vietnam, and Kuwait.

Richard Hirsch, (July 7), 62, of Makaati, Philippines, a former senior vice president of Louis Berger International, was sentenced to two years probation and fined $10,000 for bribing officials for more than a decade to win contracts in India, Indonesia, Vietnam, and Kuwait.

Declinations

Xylem Inc. (February 20) said in a Form 10-K filing that the DOJ and SEC informed the company they will not bring an enforcement action in connection with an FCPA investigation involving Xylem South Korea

Key Energy Services Inc. (April 28) said the Justice Department informed the company that it has closed its FCPA investigation and won't bring an enforcement action. Houston-based Key Energy said in 2014 it was investigating allegations of possible bribery involving its Mexico operations.The company also said on April 28 this year it is negotiating with the SEC enforcement division to settle the agency's investigation.

Akamai Technologies (June 7) released a letter from the DOJ saying it wouldn't bring an enforcement action against the company. The declination was one of the first two the DOJ issued under its FCPA Pilot Program. Akamai also agreed pursuant to an SEC non-prosecution agreement to pay about $652,000 in disgorgement and about $19,400 in interest to resolve FCPA offenses for bribes foreign subsidiaries paid to Chinese officials.

Nortek Inc. (June 7) released a letter from the DOJ saying it wouldn't bring an enforcement action against the company. The declination was one of the first two the DOJ issued under its FCPA Pilot Program. Nortek also agreed pursuant to an SEC non-prosecution agreement to pay about $291,000 in disgorgement and about $30,000 in interest to resolve FCPA offenses for bribes foreign subsidiaries paid to Chinese officials.

Johnson Controls Inc.  (June 21), the DOJ released a declination letter on July 21 that it sent earlier to Johnson Controls's lawyers. The DOJ said "at this time and consistent with the FCPA Pilot Program, we have closed our inquiry into this matter despite the bribery by employees of JCI's subsidiary in China."

Owens-Illinois Inc. (July 28) said in its Form 10-Q that it received correspondence from the DOJ and SEC indicating that they do not intend to take any enforcement action and have closed their inquiries into possible FCPA violations.

Cisco Systems Inc. (September 8) said that following an investigation into operations in Russia and some CIS countries, the DOJ and SEC won't bring FCPA enforcement actions. Cisco disclosed in March 2014 that at the request of the agencies, it was investigating allegations of FCPA violations involving the company and some of its resellers.

Harris Corporation (September 13). In connection with the Jun Ping Zhang enforcement action (see above), the SEC said it "determined not to bring charges against Harris, taking into consideration the company’s efforts at self-policing that led to the discovery of Ping’s misconduct shortly after the acquisition, prompt self-reporting, thorough remediation, and exemplary cooperation with the SEC’s investigation."

GlaxoSmithKline plc (September 30) said in a statement emailed to the FCPA Blog that the Justice Department "concluded its investigation into these matters and will be taking no further action." The matters referred to in the statement are the FCPA offenses resolved with the SEC on September 30 (see above).

Grifols SA (October 7) said it received notice from the Justice Department that an investigation into possible FCPA violations has been closed and the company won't be prosecuted. Barcelona-based Grifols reported another DOJ declination in December 2012.

Quanta Services Inc. (October 27), the company said in its Form 10-Q filed on November 8 that the SEC notified Quanta that it had concluded its investigation and, based on the information received, did not intend to pursue further action in connection with an FCPA investigation in Africa and the United Arab Emirates, among other places. 

Fairmount Santrol Holdings Inc. (November 3), the company said in a Form 8-K filed on November 17 that it was notified by the SEC that the SEC staff completed an investigation regarding possible violations of the FCPA and that the SEC does not intend to pursue enforcement action against the company.

DPA Breached

Biomet (June 6) breached a 2012 deferred prosecution agreement "based on conduct in Brazil and Mexico," according to a status report the DOJ filed in federal court on June 6. The filing also cited Biomet’s failure to maintain an effective FCPA compliance program. Biomet -- now Zimmer Biomet Holdings Inc. -- said earlier this year the three-year deferred prosecution agreement had been extended twice.

Related Non-FCPA Actions

Maria de los Angeles Gonzalez de Hernandez (January 18), 57, a former vice president at Venezuela state-owned Banco de Desarrollo Economico y Social de Venezuela (Bandes), was sentenced to time served for taking at least $5 million in bribes from Direct Access Partners, a Wall Street broker-dealer, in exchange for trading business. She had served 16-1/2 months in jail after her arrest in Miami in 2013. She pleaded guilty in late 2013 to conspiracy to violate the Travel Act and commit money laundering, and two substantive counts of the offenses. She was also ordered to forfeit $5 million. Five officers and employees from Direct Access Partners pleaded guilty and were sentenced to prison for bribing Gonzalez.

Ramiro Ascencio Nevarez (March 4), 58, a Mexican citizen and former government official, pleaded guilty to one count of conspiracy to commit money laundering. He admitted taking bribes from Douglas Ray et al (see above). He was sentenced to 15 months in prison on May 27.

Jose Luis Ramos Castillo, 38, Christian Javier Maldonado Barillas, 39, and Alfonzo Eliezer Gravina Munoz, 53 (March 22), all from Katy, Texas, were former employees of Petroleos de Venezuela S.A. (PDVSA). Their guilty pleas entered in December 2015 were unsealed. They pleaded guilty to conspiracy to commit money laundering. When they worked for PDVSA, they took bribes from Abraham Jose Shiera Bastidas (see above) in exchange for help winning contracts. Gravina also pleaded guilty to making false statements on his 2010 U.S. federal income tax return.

Ernesto Hernandez Montemayor (December 9), 55, a Mexican citizen and former government official, pleaded guilty to one count of conspiracy to commit money laundering. He admitted taking bribes from Douglas Ray et al (see above). He's scheduled to be sentenced on January 12.

Mahmoud Thiam (December 13), 50, a U.S. citizen living in New York City, was charged with two counts of money laundering. Thiam was Guinea's minister of mines from early 2009 until late 2010. The DOJ accused him of using a Hong Kong bank account to launder $8.5 million in bribes from a Chinese conglomerate.

*     *     *

Our 2015 FCPA Enforcement Index is here.

2014 is here.

2013 is here.

2012 is here.

2011 is here.

2010 is here.

2009 is here.

2008 is here.

All of our lists are here.

___________

Richard L. Cassin is the publisher and editor of the FCPA Blog.

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