International Bribe Lawyer Jason Coomer Works With Clients and Other Lawyers Around The World to Expose International Bribes and Other Violations of the Foreign Corrupt Practices Act: International Bribe Whistleblowers Can Confidentially Expose Large Bribery Schemes and Earn Large Financial Rewards by International Bribe Lawyer Lawyer Jason Coomer

Over the past decade many countries around the World have enacted anti-bribery and anti-corruption laws that prevent multinational corporations and other powerful interests from bribing government officials to obtain government contracts and for other government benefits.  These laws have helped expose several billion dollars in corruption and have forced several large corporations to pay billions for their corrupt practices.  By combining these anti-bribery laws with some bounty action and whistleblower laws that have been enacted in the United States, some individuals can not only expose large bribery schemes, but can also potentially collect large rewards for exposing large international bribery schemes.  These reward laws can be extremely complicated and usually require original information of the bribery scheme which is not known by the press or available to the public.  These reward laws also require the bribery schemes or violations of the Foreign Corrupt Practices Act to be extremely large over at least $1 million and typically well over $10 million.  The reward laws also typically have a first to file provision that means that the first person or corporation to properly expose the illegal conduct is who can recover the reward.  There are several reward laws and each has several requirements and restrictions.  For this reason, it is common for attorneys from around the World to work together on these large cases.  For the attorney or law firm outside of the United States, it can be advantageous to have a lawyer or law firm in the United States that is familiar with these reward laws and understands how some of these rewards can be claimed anonymously.  Likewise, it can also be advantageous to have a lawyer or law firm in another country where the client is and that is familiar with the location where the bribery scheme is taking place.

If you are aware of a large international bribery scheme or other significant violations of the Foreign Corrupt Practice Act (FCPA) or have a client who has this information, please feel free to contact International Bribe Lawyer Jason Coomer via e-mail message or use our submission form to begin a review or a discussion about a potential SEC Foreign Corrupt Practices Act Whistleblower Bounty Action.  Any and all communications are kept confidential and will be protected under the Attorney Client privilege as long as the communications are in anticipation of potential representation and protected from the potential client's or potential attorney's end.  Please also feel free to go to the International Whistleblower Reward Information Center for more information on International Bribe Rewards and International Collaborations.

Large Financial Rewards are Being Offered to Whistleblowers Who Properly and Confidentially Expose Large International Bribery Schemes and Other Violations of the Foreign Corrupt Practices Act

Large financial rewards are being offered to whistleblowers who properly expose large international bribery schemes.  These whistleblowers can work through an international bribe lawyer and have their identity protected.  Through the Foreign Corrupt Practices Act (FCPA), Dodd Frank Act, and SEC rules these whistleblowers that expose bribery of foreign officials by U.S. companies and foreign companies listed on the U.S. securities exchange can collect significant rewards.  These bounties have been designed to protect international professionals with original knowledge of corruption, bribes, and other violations of the Foreign Corrupt Practices Act.

Under the Foreign Corrupt Practices Act and the SEC Whistleblower Incentive Program, whistleblowers with original and specialized knowledge and evidence of corporate bribery and illegal kickbacks are eligible to recover large economic awards.  By gathering this evidence and going through a lawyer, these whistleblowers can protect their identity through the process and potential collect large rewards of 10% to 30% of the monetary sanctions including disgorged funds.  Below are some examples of recent FCPA recoveries by the SEC.  Many are well over $100 millions making potential rewards extremely large.

Telecommunications Company Paying $965 Million For FCPA Violations Washington D.C., Sept. 21, 2017 �

Sweden-based telecommunications provider Telia Company AB has agreed to pay $965 million in a global settlement with the Securities and Exchange Commission, U.S. Department of Justice, and Dutch and Swedish law enforcement to resolve charges related to violations of the Foreign Corrupt Practices Act (FCPA) to win business in Uzbekistan.  According to the SEC�s order, Telia entered the Uzbek telecommunications market by offering and paying at least $330 million in bribes to a shell company under the guise of payments for lobbying and consulting services that never actually occurred.  The shell company was controlled by an Uzbek government official who was a family member of the President of Uzbekistan and in a position to exert significant influence over other Uzbek officials, causing them to take official actions to benefit Telia�s business in Uzbekistan.
�Corporate bribery is not just unfair and illegal, it has terribly corrosive effects on business, government, and society,� said Stephanie Avakian, Co-Director of the SEC�s Enforcement Division.  �As this global settlement demonstrates, the SEC continues to work closely with our counterparts at home and abroad to expose and pursue such corruption.�

Telia consented to the SEC�s order requiring the company to pay $457 million in disgorgement, and the company also agreed to pay a criminal fine of more than $508 million imposed by the Department of Justice.  Portions of each amount could be offset by payments made in overseas settlements or proceedings brought by the Dutch Openbaar Ministerie or the Swedish �klagarmyndigheten.  Telia�s overall payment to the four agencies must be at least $965 million.
 

The SEC appreciates the assistance of the Department of Justice Criminal Division�s Fraud and Money Laundering and Asset Recovery Sections as well as the Internal Revenue Service, Department of Homeland Security, Dutch Openbaar Ministerie, National Authority for Investigation and Prosecution of Economic and Environmental Crime in Norway, Swedish Prosecution Authority, Office of the Attorney General in Switzerland, and Corruption Prevention and Combating Bureau in Latvia.  The SEC also appreciates the assistance from regulators and law enforcement in France, Spain, and Hong Kong as well as the Financial Conduct Authority, British Virgin Islands Financial Services Commission, Cayman Islands Monetary Authority, Bermuda Monetary Authority, Cyprus Securities and Exchange Commission, and Central Bank of Ireland.

Halliburton Paying $29.2 Million to Settle FCPA Violations Washington D.C., July 27, 2017

The Securities and Exchange Commission today charged Halliburton Company with violating the books and records and internal accounting controls provisions of the Foreign Corrupt Practices Act (FCPA) while selecting and making payments to a local company in Angola in the course of winning lucrative oilfield services contracts.

Halliburton, which profited by approximately $14 million from the deals, has agreed to pay more than $29.2 million to settle the SEC�s case.  The company also agreed to obtain an independent compliance consultant to oversee its anti-corruption policies and procedures in Africa.  Halliburton�s former vice president Jeannot Lorenz has agreed to pay a $75,000 penalty for causing the company�s violations, circumventing internal accounting controls, and falsifying books and records.
According to the SEC�s order, officials at Angola�s state oil company Sonangol advised Halliburton management in 2008 that it was required to partner with more local Angolan-owned businesses to satisfy local content regulations for foreign firms operating in Angola.  Halliburton tasked Lorenz to spearhead these efforts.  When a new round of oil company projects came up for bid, Lorenz began a lengthy effort to retain a local Angolan company owned by a former Halliburton employee who was a friend and neighbor of the Sonangol official who would ultimately approve the award of the contracts.  It took three attempts but Halliburton ultimately outsourced more than $13 million worth of business to the local Angolan company.

The SEC�s order finds that Halliburton entered into contracts with the local Angolan company that were intended to meet local content requirements rather than the stated scope of work.  Lorenz violated Halliburton�s internal accounting controls by starting with the local Angolan company and then backing into a list of contract services rather than first determining the services and then selecting an appropriate supplier.  Lorenz also failed to conduct competitive bidding or substantiate the need for a single source of supply, and he avoided an internal accounting control that required contracts of more than $10,000 in countries like Angola with high corruption risks to be reviewed and approved by a special committee within Halliburton.  The company eventually paid $3.705 million to the local Angolan firm, and Sonangol approved the award of seven lucrative subcontracts to Halliburton.
�Halliburton committed to using a particular supplier that posed significant FCPA risks and a company vice president circumvented important internal accounting controls to get the deal done quickly,� said Antonia Chion, Associate Director in the SEC�s Enforcement Division.  �Companies and their executives must comply with these internal accounting controls that help ensure the integrity of corporate transactions.�

Without admitting or denying the findings, Halliburton and Lorenz consented to the order requiring them to cease and desist from committing or causing any violations or any future violations of the books and records and internal accounting controls provisions of the FCPA.  Halliburton agreed to pay $14 million in disgorgement plus $1.2 million in prejudgment interest and a $14 million penalty.  Halliburton must retain an independent compliance consultant for 18 months to review and evaluate its anti-corruption policies and procedures, particularly in regard to local content obligations for business operations in Africa.
The SEC�s investigation was conducted by Ansu N. Banerjee and Steven A. Susswein with assistance from Alfred Day and Thomas Bednar.  The case was supervised by Melissa R. Hodgman and Ms. Chion.  The SEC appreciates the assistance of the U.S. Department of Justice and the Federal Bureau of Investigation.

Biomet Charged With Repeating FCPA Violations Washington D.C., Jan. 12, 2017
 
The Securities and Exchange Commission today announced that a Warsaw, Ind.-based medical device manufacturer has agreed to pay more than $30 million to resolve parallel SEC and Department of Justice investigations into the company�s repeat violations of the Foreign Corrupt Practices Act (FCPA).
Biomet first faced FCPA charges from the SEC and entered into a deferred prosecution agreement with the Department of Justice in March 2012, agreeing to pay more than $22 million to settle both cases.  As part of the SEC settlement, Biomet agreed to retain an independent compliance consultant to review its FCPA compliance program.  After the settlement as Biomet was implementing recommendations from the independent monitor, the company learned about potential anti-bribery violations in Brazil and Mexico and notified the monitor and the SEC in 2013.

The SEC�s order finds that Biomet continued to interact and improperly record transactions with a known prohibited distributor in Brazil, and used a third-party customs broker to pay bribes to Mexican customs officials to facilitate the importation and smuggling of unregistered and mislabeled dental products.
�Biomet didn�t entirely learn its lesson the first time around as it continued to use a prohibited agent in Brazil and engaged in a new bribery scheme in Mexico,� said Kara Brockmeyer, Chief of the SEC Enforcement Division�s FCPA Unit.

Biomet, which has since been acquired by Zimmer Holdings and renamed Zimmer Biomet, agreed to pay more than $5.82 million in disgorgement plus $702,705 in interest and a $6.5 million penalty for a total of more than $13 million.  Zimmer Biomet also agreed to retain an independent compliance monitor for a three-year period to review its FCPA policies.  As part of the deferred prosecution agreement with the Department of Justice, Zimmer Biomet agreed to pay a fine of more than $17.46 million.

The SEC�s investigation was conducted by Michelle L. Ramos, Robert Dodge, and Shahriar Masud.  The case was supervised by Tracy L. Price.  The SEC appreciates the assistance of the Department of Justice Criminal Division�s Fraud Section and the Federal Bureau of Investigation

Chemical and Mining Company in Chile Paying $30 Million to Resolve FCPA Cases Washington D.C., Jan. 13, 2017

The Securities and Exchange Commission today announced that Chilean-based chemical and mining company Sociedad Quimica y Minera de Chile S.A. (SQM) agreed to pay more than $30 million to resolve parallel civil and criminal cases finding that it violated the Foreign Corrupt Practices Act (FCPA).
According to the SEC�s order, SQM made nearly $15 million in improper payments to Chilean political figures and others connected to them.  Most of the payments were made based on fake documentation submitted to SQM by individuals and entities posing as legitimate vendors.  The payments occurred for at least a seven-year period.

�SQM permitted millions of dollars in payments to local politicians while failing for years to exercise proper oversight over a key discretionary account and internal controls,� said Stephanie Avakian, Acting Director of the SEC Enforcement Division.

SQM agreed to pay a $15 million penalty to settle the SEC�s charges and a $15.5 million penalty as part of a deferred prosecution agreement announced today by the U.S. Department of Justice.  SQM agreed to retain an independent compliance monitor for two years and self-report to the SEC and Justice Department for one year after the monitor�s work is complete.

The SEC�s investigation, which is continuing, is being conducted by William B. McKean.  The SEC appreciates the assistance of the Department of Justice Criminal Division�s Fraud Section.

Chemical and Mining Company in Chile Paying $30 Million to Resolve FCPA Cases Washington D.C., Jan. 13, 2017

The Securities and Exchange Commission today announced that Chilean-based chemical and mining company Sociedad Quimica y Minera de Chile S.A. (SQM) agreed to pay more than $30 million to resolve parallel civil and criminal cases finding that it violated the Foreign Corrupt Practices Act (FCPA).
According to the SEC�s order, SQM made nearly $15 million in improper payments to Chilean political figures and others connected to them.  Most of the payments were made based on fake documentation submitted to SQM by individuals and entities posing as legitimate vendors.  The payments occurred for at least a seven-year period.
 

�SQM permitted millions of dollars in payments to local politicians while failing for years to exercise proper oversight over a key discretionary account and internal controls,� said Stephanie Avakian, Acting Director of the SEC Enforcement Division.
SQM agreed to pay a $15 million penalty to settle the SEC�s charges and a $15.5 million penalty as part of a deferred prosecution agreement announced today by the U.S. Department of Justice.  SQM agreed to retain an independent compliance monitor for two years and self-report to the SEC and Justice Department for one year after the monitor�s work is complete.
 

The SEC�s investigation, which is continuing, is being conducted by William B. McKean.  The SEC appreciates the assistance of the Department of Justice Criminal Division�s Fraud Section.

Teva Pharmaceutical Paying $519 Million to Settle FCPA Charges Washington D.C., Dec. 22, 2016
 
The Securities and Exchange Commission today announced that Teva Pharmaceutical Industries Limited has agreed to pay more than $519 million to settle parallel civil and criminal charges that it violated the Foreign Corrupt Practices Act by paying bribes to foreign government officials in Russia, Ukraine, and Mexico.

The SEC�s complaint alleges that Teva made more than $214 million in illicit profits by making the influential payments to increase its market share and obtain regulatory and formulary approvals as well as favorable drug purchase and prescription decisions.
�As alleged in our complaint, Teva failed to devise and maintain proper internal accounting controls to prevent the company�s payments of bribes to win business in certain regions around the globe,� said Stephanie Avakian, Deputy Director of the SEC Enforcement Division.
Eric I. Bustillo, Director of the SEC�s Miami Regional Office, added, �As we allege in our complaint, many of these bribes were concealed as legitimate payments to distributors.  While distributors can help companies navigate complex regulatory environments and provide valuable industry relationships, they also can create significant corruption risks for companies.�

Under the settlement, Teva must pay more than $236 million in disgorgement and interest to the SEC plus a $283 million penalty in a deferred prosecution agreement with the U.S. Department of Justice.  Teva must retain an independent corporate monitor for at least three years.
The SEC�s investigation was conducted by Jenny Trotman with assistance from Kathleen Strandell and Russell Koonin in the Miami Regional Office.  The case was supervised by Thierry Olivier Desmet of the FCPA Unit.  The SEC appreciates the assistance of the Department of Justice Criminal Division�s Fraud Section, Federal Bureau of Investigation, and Financial Services Commission of the British Virgin Islands.

Petrochemical Manufacturer Braskem S.A. to Pay $957 Million to Settle FCPA Charges Washington D.C., Dec. 21, 2016
 
The Securities and Exchange Commission today announced that a Brazilian-based petrochemical manufacturer whose stock trades in the U.S. markets has agreed to settle charges that it created false books and records to conceal millions of dollars in illicit bribes paid to Brazilian government officials to win or retain business.

In a global settlement with the SEC, U.S. Department of Justice, and authorities in Brazil and Switzerland, Braskem S.A. agreed to pay $957 million.
The SEC�s complaint alleges that Braskem made approximately $325 million in profits through bribes paid through intermediaries and off-book accounts managed by a private company that was Braskem�s largest shareholder.  Bribes were paid to a government official at Brazil�s state-controlled petroleum company as well as Brazilian legislators and political party officials.

�As alleged in our complaint, Braskem lacked the internal controls to prevent its use of third parties, off-book accounts, and other intermediaries to bribe government officials in Brazil during an eight-year period,� said Stephanie Avakian, Deputy Director of the SEC Enforcement Division.  �Braskem�s misconduct was exposed through the investigative work of authorities in three countries.�

Braskem agreed to pay $325 million in disgorgement, including $65 million to the SEC and $260 million to Brazilian authorities.  Braskem agreed to pay more than $632 million in criminal penalties and fines.  The company must retain an independent corporate monitor for at least three years.
The SEC�s investigation is continuing.  It is being conducted by Ernesto Palacios and Thierry Olivier Desmet of the FCPA Unit with assistance from David S. Johnson and Fernando Torres, and supervised by Kara Brockmeyer, Chief of the FCPA Unit.  The SEC appreciates the assistance of the Department of Justice Criminal Division�s Fraud Section, the Federal Bureau of Investigation, the Brazilian Federal Prosecution Service, the Brazilian Federal Police, and the Office of the Attorney General in Switzerland. 

VimpelCom to Pay $795 Million in Global Settlement for FCPA Violations Washington D.C., Feb. 18, 2016
 
The Securities and Exchange Commission today announced a global settlement along with the U.S. Department of Justice and Dutch regulators that requires telecommunications provider VimpelCom Ltd. to pay more than $795 million to resolve its violations of the Foreign Corrupt Practices Act (FCPA) to win business in Uzbekistan.

The SEC alleges that VimpelCom offered and paid bribes to an Uzbek government official related to the President of Uzbekistan as the company entered the Uzbek telecommunications market and sought government-issued licenses, frequencies, channels, and number blocks.  At least $114 million in bribe payments were funneled through an entity affiliated with the Uzbek official, and approximately a half-million dollars in bribes were disguised as charitable donations made to charities directly affiliated with the Uzbek official.

�VimpelCom made massive revenues in Uzbekistan by paying over $100 million to an official with significant influence over top leaders of the Uzbek government,� said Andrew J. Ceresney, Director of the SEC Enforcement Division.  �These old-fashioned bribes, hidden through sham contracts and charitable contributions, left the company�s books and records riddled with inaccuracies.�

The settlement requires VimpelCom to pay $167.5 million to the SEC, $230.1 million to the U.S. Department of Justice, and $397.5 million to Dutch regulators.  The company must retain an independent corporate monitor for at least three years.

�International cooperation among regulators is critical to holding companies responsible for all facets of a bribery scheme.  This closely coordinated settlement is a product of the extraordinary efforts of the SEC, Department of Justice, and law enforcement partners around the globe to jointly pursue those who break the law to win business,� said Kara N. Brockmeyer, Chief of the SEC Enforcement Division�s FCPA Unit.

The SEC�s complaint was filed in U.S. District Court for the Southern District of New York.  VimpelCom consented to the entry of a court order ordering the company to pay disgorgement and retain an independent monitor, and permanently enjoining the company from future violations of Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934.

The SEC�s continuing investigation is being conducted by the FCPA Unit under the supervision of its Deputy Chief Charles Cain.  The SEC appreciates the significant assistance of the Department of Justice�s Criminal Division, Fraud and Asset Forfeiture Money Laundering Sections as well as the following agencies: Internal Revenue Service, Department of Homeland Security, Public Prosecution Service of the Netherlands (Openbaar Ministrie), National Authority for Investigation and Prosecution of Economic and Environmental Crime in Norway (�KOKRIM), Swedish Prosecution Authority, Office of the Attorney General in Switzerland, and Corruption Prevention and Combating Bureau in Latvia.  Other valuable assistance was provided by the British Virgin Islands Financial Services Commission, Caymans Islands Monetary Authority, Bermuda Monetary Authority, and Central Bank of Ireland, Estonia Financial Supervisory Authority (Finantsinspektioon), Comisi�n Nacional del Mercado de Valores (Spain), Latvian Financial and Capital Market Commission, UAE Securities and Commodities Authority, Banking Commission of the Marshall Islands, and Gibraltar Financial Services Commission.

JPMorgan Chase Paying $264 Million to Settle FCPA Charges Washington D.C., Nov. 17, 2016

The Securities and Exchange Commission today announced that JPMorgan Chase & Co. has agreed to pay more than $130 million to settle SEC charges that it won business from clients and corruptly influenced government officials in the Asia-Pacific region by giving jobs and internships to their relatives and friends in violation of the Foreign Corrupt Practices Act (FCPA).

JPMorgan also is expected to pay $72 million to the Justice Department and $61.9 million to the Federal Reserve Board of Governors for a total of more than $264 million in sanctions resulting from the firm�s referral hiring practices.
According to an SEC order issued today, investment bankers at JPMorgan�s subsidiary in Asia created a client referral hiring program that bypassed the firm�s normal hiring process and rewarded job candidates referred by client executives and influential government officials with well-paying, career-building JPMorgan employment.  During a seven-year period, JPMorgan hired approximately 100 interns and full-time employees at the request of foreign government officials, enabling the firm to win or retain business resulting in more than $100 million in revenues to JPMorgan.

�JPMorgan engaged in a systematic bribery scheme by hiring children of government officials and other favored referrals who were typically unqualified for the positions on their own merit,� said Andrew J. Ceresney, Director of the SEC Enforcement Division.  �JPMorgan employees knew the firm was potentially violating the FCPA yet persisted with the improper hiring program because the business rewards and new deals were deemed too lucrative.�

Kara Brockmeyer, Chief of the SEC Enforcement Division�s FCPA Unit, added, �The misconduct was so blatant that JPMorgan investment bankers created �Referral Hires vs Revenue� spreadsheets to track the money flow from clients whose referrals were rewarded with jobs.  The firm�s internal controls were so weak that not a single referral hire request was denied.�

The SEC�s order finds that JPMorgan violated the anti-bribery, books and records, and internal controls provisions of the Securities Exchange Act of 1934.  JPMorgan agreed to pay $105,507,668 in disgorgement plus $25,083,737 in interest to settle the SEC�s case.  The SEC considered the company�s remedial acts and its cooperation with the investigation when determining the settlement.

The SEC�s continuing investigation is being conducted by Neil Smith and Paul Block of the FCPA Unit and Rory Alex and Martin Healey of the Boston Regional Office.  The SEC appreciates the assistance of the Fraud Section of the U.S. Department of Justice, the U.S. Attorney�s Office for the Eastern District of New York, the Federal Bureau of Investigation, and the Federal Reserve Board of Governors.

Embraer Paying $205 Million to Settle FCPA Charges Washington D.C., Oct. 24, 2016
 
The Securities and Exchange Commission today announced a global settlement along with the U.S. Department of Justice and Brazilian authorities that requires aircraft manufacturer Embraer S.A. to pay more than $205 million to resolve alleged violations of  the Foreign Corrupt Practices Act (FCPA).

The SEC�s complaint alleges that Embraer made more than $83 million in profits as a result of bribe payments from its U.S.-based subsidiary through third-party agents to foreign government officials in the Dominican Republic, Saudi Arabia, and Mozambique.  Embraer allegedly created false books and records to conceal the illicit payments, and also engaged in an alleged accounting scheme in India.

According to the SEC�s complaint, $3.52 million in bribes were paid to an official in the Dominican Republic�s air force to secure a military aircraft contract in that country, and $1.65 million in bribes were routed to an official in Saudi Arabia to win business there.  An alleged $800,000 payment was made at the behest of a Mozambican government official as a condition of obtaining a contract with a state-owned airline in that country.  Approximately $5.76 million was allegedly paid to an agent in India in connection with the sale of three highly specialized military aircraft for India�s air force, and the payments were falsely recorded in Embraer�s books and records as part of a consulting agreement that wasn�t legitimate.

�As alleged in our complaint, Embraer realized significant revenues by surreptitiously using third parties to mask bribes paid to government officials with influence over contracts it was competing to win,� said Andrew J. Ceresney, Director of the SEC Enforcement Division.
Kara N. Brockmeyer, Chief of the SEC Enforcement Division�s FCPA Unit, added, �Embraer�s alleged misconduct spanned multiple continents, and it has taken significant ongoing coordination among international regulators and law enforcement agencies to uncover the company�s complex bribery schemes.�
Under the settlement, Embraer must pay a $107 million penalty to the Justice Department as part of a deferred prosecution agreement, and more than $98 million in disgorgement and interest to the SEC. Embraer may receive up to a $20 million credit depending on the amount of disgorgement it will pay to Brazilian authorities in a parallel civil proceeding in Brazil.  Embraer must retain an independent corporate monitor for at least three years.

The SEC�s investigation was conducted by Ernesto Palacios and Thierry Olivier Desmet of the FCPA Unit with assistance from Kathleen Strandell.  The SEC appreciates the assistance of the Department of Justice Criminal Division�s Fraud Section, the Federal Bureau of Investigation, the Brazilian Federal Prosecution Service, the Brazilian Federal Police, Brazil�s Comiss�o de Valores Mobili�rios, the South African Financial Services Board, the Swiss Financial Market Supervisory Authority (FINMA), the Banco Central del Uruguay, the Spanish Comisi�n Nacional del Mercado de Valores, and the French Autorit� des March�s Financiers.

Och-Ziff Hedge Fund Settles FCPA Charges Och-Ziff Executives Also Settle Charges Washington D.C., Sept. 29, 2016

The Securities and Exchange Commission today announced that Och-Ziff Capital Management Group has agreed to pay nearly $200 million to the SEC to settle civil charges of violating the Foreign Corrupt Practices Act (FCPA).
Och-Ziff CEO Daniel S. Och agreed to pay nearly $2.2 million to settle SEC charges that he caused certain violations along with CFO Joel M. Frank, who also agreed to settle the charges.

The SEC detected the misconduct while proactively scrutinizing the way that financial services firms were obtaining investments from sovereign wealth funds overseas.  The SEC�s subsequent investigation of Och-Ziff found that the fund used intermediaries, agents, and business partners to pay bribes to high-level government officials in Africa.  According to the SEC�s order, the illicit payments induced the Libyan Investment Authority sovereign wealth fund to invest in Och-Ziff managed funds.  Other bribes were paid to secure mining rights and corruptly influence government officials in Libya, Chad, Niger, Guinea, and the Democratic Republic of the Congo.The SEC�s order finds that Och-Ziff executives ignored red flags and corruption risks and permitted illicit transactions to proceed.
 
�Och-Ziff engaged in complicated, far-reaching schemes to get special access and secure significant deals and profits through corruption,� said Andrew J. Ceresney, Director of the SEC Enforcement Division. �Senior executives cannot turn a blind eye to the acts of their employees or agents when they became aware of suspicious transactions with high-risk partners in foreign countries.�
 
The SEC�s order finds that Och-Ziff�s books and records did not accurately describe the true purposes for which managed investor funds were used, and the company did not have adequate internal controls to detect or prevent the bribes.
 
�Och-Ziff falsely recorded the bribe payments and failed to devise and maintain proper internal controls,� said Kara Brockmeyer, Chief of the SEC Enforcement Division�s FCPA Unit.  �Firms will be held accountable for their misconduct no matter how they might structure complex transactions or attempt to insulate themselves from the conduct of their employees or agents.�
 
The SEC�s order finds Och-Ziff violated the anti-bribery, books and records, and internal controls provisions of the Securities Exchange Act of 1934, and affiliated investment adviser OZ Management violated the anti-fraud provisions of the Investment Advisers Act of 1940.  Och-Ziff and OZ Management agreed to pay $173,186,178 in disgorgement plus $25,858,989 in interest for a total of $199,045,167.  The order finds that Och caused violations in two Och-Ziff transactions in the Democratic Republic of the Congo, and he agreed to pay $1.9 million in disgorgement and $273,718 in interest to settle the charges.  The order finds that Frank caused violations in Och-Ziff transactions in Libya and the Democratic Republic of the Congo, and a penalty will be assessed against him at a future date.  Och and Frank consented to the SEC�s order without admitting or denying the findings.
 
As part of its settlement agreement with the SEC, Och-Ziff acknowledged that it expected to enter into a deferred prosecution agreement with the Justice Department in a parallel criminal proceeding, and its subsidiary OZ Africa Management GP LLC agreed to enter into a plea agreement.  Och-Ziff is expected to pay a criminal penalty of $213 million.
 
The SEC�s investigation is continuing.  It is being conducted by Neil Smith and Paul Block of the FCPA Unit and Rory Alex, Marc Jones, and Martin Healey of the Boston Regional Office.  The SEC appreciates the assistance of the Fraud Section of the U.S. Department of Justice, the U.S. Attorney�s Office for the Eastern District of New York, the Federal Bureau of Investigation, and the Internal Revenue Service�s Criminal Investigations Division as well as the assistance of the United Kingdom�s Financial Conduct Authority, the Guernsey Financial Services Commission, the Jersey Financial Services Commission, the Malta Financial Services Authority, the Cyprus Securities and Exchange Commission, the Gibraltar Financial Services Commission, and the Swiss Ministry of Justice.

SEC Charges Avon With FCPA Violations Avon Entities to Pay $135 Million to Settle SEC and Criminal Cases Washington D.C., Dec. 17, 2014
 
The Securities and Exchange Commission today charged global beauty products company Avon Products Inc. with violating the Foreign Corrupt Practices Act (FCPA) by failing to put controls in place to detect and prevent payments and gifts to Chinese government officials from employees and consultants at a subsidiary.

Avon entities agreed to pay a total of $135 million to settle the SEC�s charges and a parallel case announced today by the U.S. Department of Justice and the U.S. Attorney�s Office for the Southern District of New York.

The SEC alleges that Avon�s subsidiary in China made $8 million worth of payments in cash, gifts, travel, and entertainment to gain access to Chinese officials implementing and overseeing direct selling regulations in China.  Avon sought to be among the first allowed to test the regulations, and eventually received the first direct selling business license in China in March 2006.  The improper payments also were made to avoid fines or negative news articles that could have impacted Avon�s clean corporate image required to retain the license.  Examples of improper payments alleged in the SEC�s complaint include paid travel for Chinese government officials within China or to the U.S. or Europe as well as such gifts as Louis Vuitton merchandise, Gucci bags, Tiffany pens, and corporate box tickets to the China Open tennis tournament.

�Avon�s subsidiary in China paid millions of dollars to government officials to obtain a direct selling license and gain an edge over their competitors, and the company reaped substantial financial benefits as a result,� said Scott W. Friestad, an Associate Director in the SEC�s Division of Enforcement.  �Avon missed an opportunity to correct potential FCPA problems at its subsidiary, resulting in years of additional misconduct that could have been avoided.�

According to the SEC�s complaint filed in U.S. District Court for the Southern District of New York, the improper payments occurred from 2004 to 2008.  Avon management learned about potential FCPA problems at the subsidiary through an internal audit report in late 2005.  Avon management consulted an outside law firm, directed that reforms be instituted at the subsidiary, and sent an internal audit team to follow up.  Ultimately, however, no such reforms were instituted at the Chinese subsidiary.  Avon finally began a full-blown internal investigation in 2008 after its CEO received a letter from a whistleblower.

The SEC alleges that Avon�s books and records failed to accurately record the details and purpose of the payments.  In some instances, payments were concealed by falsely recording the transactions as employee business expenses or as reimbursement of a third-party vendor.  In other instances, the records for the payments set forth almost no detail at all.  The resulting books and records did not allow a reviewer to ascertain the government official or state-owned entities that received the payments or the purpose for which the payments were made.

The SEC�s complaint charges Avon with violating Sections 13(b)(2)(A) and 13(b)(2)(B) of the Securities Exchange Act of 1934.  Avon agreed to pay disgorgement of $52,850,000 in benefits resulting from the alleged misconduct plus prejudgment interest of $14,515,013.13 for a total of more than $67.36 million.  In the parallel criminal matter, Avon entities agreed to pay $67,648,000 in penalties.  Avon also is required to retain an independent compliance monitor to review its FCPA compliance program for a period of 18 months, followed by an 18-month period of self-reporting on its compliance efforts.  Avon would be permanently enjoined from violating the books and records and internal controls provisions of the federal securities laws.  In reaching the proposed settlement, which is subject to court approval, the SEC considered Avon�s cooperation and significant remedial measures.

The SEC�s investigation was conducted by Paul W. Sharratt and Roger Paszamant and supervised by David Frohlich.  The SEC appreciates the assistance of the Fraud Section of the Department of Justice, the U.S. Attorney�s Office for the Southern District of New York, and the Federal Bureau of Investigation.
 

SEC Charges Alcoa With FCPA Violations FOR IMMEDIATE RELEASE 2014-3 Washington D.C., Jan. 9, 2014

The Securities and Exchange Commission today charged global aluminum producer Alcoa Inc. with violating the Foreign Corrupt Practices Act (FCPA) when its subsidiaries repeatedly paid bribes to government officials in Bahrain to maintain a key source of business.

An SEC investigation found that more than $110 million in corrupt payments were made to Bahraini officials with influence over contract negotiations between Alcoa and a major government-operated aluminum plant.  Alcoa�s subsidiaries used a London-based consultant with connections to Bahrain�s royal family as an intermediary to negotiate with government officials and funnel the illicit payments to retain Alcoa�s business as a supplier to the plant.  Alcoa lacked sufficient internal controls to prevent and detect the bribes, which were improperly recorded in Alcoa�s books and records as legitimate commissions or sales to a distributor.

Alcoa agreed to settle the SEC�s charges and a parallel criminal case announced today by the U.S. Department of Justice by paying a total of $384 million.

�As the beneficiary of a long-running bribery scheme perpetrated by a closely controlled subsidiary, Alcoa is liable and must be held responsible,� said George Canellos, co-director of the SEC Enforcement Division.  �It is critical that companies assess their supply chains and determine that their business relationships have legitimate purposes.�

Kara N. Brockmeyer, chief of the SEC Enforcement Division�s FCPA Unit added, �The extractive industries have historically been exposed to a high risk of corruption, and those risks are as real today as when the FCPA was first enacted.�

According to the SEC�s order instituting settled administrative proceedings, Alcoa is a global provider of not only primary or fabricated aluminum, but also smelter grade alumina � the raw material that is supplied to plants called smelters that produce aluminum.  Alcoa refines alumina from bauxite that it extracts in its global mining operations.  From 1989 to 2009, one of the largest customers of Alcoa�s global bauxite and alumina refining business was Aluminium Bahrain B.S.C. (Alba), which is considered one of the largest aluminum smelters in the world.  Alba is controlled by Bahrain�s government, and Alcoa�s mining operations in Australia were the source of the alumina that Alcoa supplied to Alba.

According to the SEC�s order, Alcoa�s Australian subsidiary retained a consultant to assist in negotiations for long-term alumina supply agreements with Alba and Bahraini government officials.  A manager at the subsidiary described the consultant as �well versed in the normal ways of Middle East business� and one who �will keep the various stakeholders in the Alba smelter happy��  Despite the red flags inherent in this arrangement, Alcoa�s subsidiary inserted the intermediary into the Alba sales supply chain, and the consultant generated the funds needed to pay bribes to Bahraini officials.  Money used for the bribes came from the commissions that Alcoa�s subsidiary paid to the consultant as well as price markups the consultant made between the purchase price of the product from Alcoa and the sale price to Alba.

The SEC�s order finds that Alcoa did not conduct due diligence or otherwise seek to determine whether there was a legitimate business purpose for the use of a middleman.  Recipients of the corrupt payments included senior Bahraini government officials, members of Alba�s board of directors, and Alba senior management.  For example, after Alcoa�s subsidiary retained the consultant to lobby a Bahraini government official, the consultant�s shell companies made two payments totaling $7 million in August 2003 for the benefit of the official.  Two weeks later, Alcoa and Alba signed an agreement in principle to have Alcoa participate in Alba�s plant expansion.  In October 2004, the consultant�s shell company paid $1 million to an account for the benefit of that same government official, and Alba went on to reach another supply agreement in principle with Alcoa.  Around the time that agreement was executed, the consultant�s companies made three payments totaling $41 million to benefit another Bahraini government official as well.

The SEC�s cease-and-desist order finds that Alcoa violated Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934.  Alcoa will pay $175 million in disgorgement of ill-gotten gains, of which $14 million will be satisfied by the company�s payment of forfeiture in the parallel criminal matter.  Alcoa also will pay a criminal fine of $209 million.

The SEC appreciates the assistance of the Fraud Section of the Criminal Division at the Department of Justice as well as the Federal Bureau of Investigation, Internal Revenue Service, Australian Federal Police, Ontario Securities Commission, Guernsey Financial Services Commission, Liechtenstein Financial Market Authority, Norwegian �KOKRIM, United Kingdom Financial Control Authority, and Office of the Attorney General of Switzerland.

SEC Charges Hewlett-Packard With FCPA Violations Company to Pay $108 Million to Settle Civil and Criminal Cases FOR IMMEDIATE RELEASE 2014-73 Washington D.C., April 9, 2014

The Securities and Exchange Commission today charged Hewlett-Packard with violating the Foreign Corrupt Practices Act (FCPA) when its subsidiaries in three different countries made improper payments to government officials to obtain or retain lucrative public contracts.

Hewlett-Packard has agreed to pay more than $108 million to settle the SEC�s charges and a parallel criminal case announced today by the U.S. Department of Justice.

The SEC�s order instituting settled administrative proceedings finds that the Palo Alto, Calif.-based technology company�s subsidiary in Russia paid more than $2 million through agents and various shell companies to a Russian government official to retain a multi-million dollar contract with the federal prosecutor�s office.  In Poland, Hewlett-Packard�s subsidiary provided gifts and cash bribes worth more than $600,000 to a Polish government official to obtain contracts with the national police agency.  And as part of its bid to win a software sale to Mexico�s state-owned petroleum company, Hewlett-Packard�s subsidiary in Mexico paid more than $1 million in inflated commissions to a consultant with close ties to company officials, and money was funneled to one of those officials.

�Hewlett-Packard lacked the internal controls to stop a pattern of illegal payments to win business in Mexico and Eastern Europe.  The company�s books and records reflected the payments as legitimate commissions and expenses,� said Kara Brockmeyer, chief of the SEC Enforcement Division�s FCPA Unit.  �Companies have a fundamental obligation to ensure that their internal controls are both reasonably designed and appropriately implemented across their entire business operations, and they should take a hard look at the agents conducting business on their behalf.�

According to the SEC�s order, the scheme involving Hewlett-Packard�s Russian subsidiary occurred from approximately 2000 to 2007.  The bribes were paid through agents and consultants in order to win a government contract for computer hardware and software.  Employees within the subsidiary and elsewhere raised questions about the significant markup being paid to the agent on the deal and the subcontractors that the agent expected to use.  Despite the red flags, the deal went forward without any meaningful due diligence on the agent or the subcontractors.

The SEC�s order finds that bribes involving Hewlett-Packard�s subsidiary in Poland occurred from approximately 2006 to 2010.  Acting primarily through its public sector sales manager, the subsidiary agreed to pay a Polish government official in order to win contracts for information technology products and services.  The official received a percentage of net revenue earned from the contracts, and the bribes were delivered in cash from off-the-books accounts.

According to the SEC�s order, Hewlett-Packard�s subsidiary in Mexico paid a consultant to help the company win a public IT contract worth approximately $6 million.  At least $125,000 was funneled to a government official at the state-owned petroleum company with whom the consultant had connections.  Although the consultant was not an approved deal partner and had not been subjected to the due diligence required under company policy, HP Mexico sales managers used a pass-through entity to pay inflated commissions to the consultant.  This was internally referred to as the �influencer fee.�

Hewlett-Packard consented to the SEC�s order, which finds that it violated the internal controls and books and records provisions of the Securities Exchange Act of 1934.  The company agreed to pay $29 million in disgorgement (approximately $26.47 million to the SEC and $2.53 million to satisfy an IRS forfeiture as part of the criminal matter).  Hewlett-Packard also agreed to pay prejudgment interest of $5 million to the SEC and fines totaling $74.2 million in the criminal case for a total of more than $108 million in disgorgement and penalties.  

The SEC�s investigation was conducted by David A. Berman and Tracy L. Davis of the FCPA Unit in San Francisco.  The SEC appreciates the assistance of the U.S. Department of Justice�s Fraud Section and the U.S. Attorney�s Office for the Northern District of California as well as the Federal Bureau of Investigation, Internal Revenue Service, and Public Prosecutor�s Office in Dresden, Germany.
 

SEC Charges Weatherford International With FCPA Violations FOR IMMEDIATE RELEASE 2013-252 Washington D.C., Nov. 26, 2013 

The Securities and Exchange Commission today charged oilfield services company Weatherford International with violating the Foreign Corrupt Practices Act (FCPA) by authorizing bribes and improper travel and entertainment for foreign officials in the Middle East and Africa to win business, including kickbacks in Iraq to obtain United Nations Oil-for-Food contracts.

The SEC alleges that Weatherford and its subsidiaries falsified its books and records to conceal not only these illicit payments, but also commercial transactions with Cuba, Iran, Syria, and Sudan that violated U.S. sanctions and export control laws.  Weatherford failed to establish an effective system of internal accounting controls to monitor risks of improper payments and prevent or detect misconduct.  The company reaped more than $59.3 million in profits from business obtained through improper payments, and more than $30 million in profits from its improper sales to sanctioned countries.

Swiss-based Weatherford, which has substantial operations in Houston, has agreed to pay more than $250 million to settle the SEC�s charges and parallel actions by the Department of Justice�s Fraud Section, U.S. Attorney�s Office for the Southern District of Texas, Department of Commerce�s Bureau of Industry and Security, and Department of Treasury�s Office of Foreign Assets Control.

�The nonexistence of internal controls at Weatherford fostered an environment where employees across the globe engaged in bribery and failed to maintain accurate books and records,� said Andrew Ceresney, co-director of the SEC�s Enforcement Division.  �They used code names like �Dubai across the water� to conceal references to Iran in internal correspondence, placed key transaction documents in mislabeled binders, and created whatever bogus accounting and inventory records were necessary to hide illegal transactions.�

Kara N. Brockmeyer, chief of the SEC Enforcement Division�s FCPA Unit, added, �Whether the money went to tax auditors in Albania or officials at the state-owned oil company in Angola, bribes and improper payments were an accustomed way for Weatherford to conduct business.  While the profits may have seemed bountiful at the time, the costs far outweigh the benefits in the end as coordinated law enforcement efforts have unraveled the widespread schemes and heavily sanctioned the misconduct.�

According to the SEC�s complaint filed in federal court in Houston, the misconduct occurred from at least 2002 to 2011.  In Angola, for example, Weatherford�s legal department permitted its subsidiary to use an agent who insisted that an FCPA clause be omitted from the consultancy agreement.  The company took no steps to determine whether the agent was paying bribes to foreign officials, and the agent used sham work orders and invoices to pay bribes that ensured the renewal of a lucrative oil services contract for Weatherford in Angola.  The same agent made illicit payments to obtain commercial contracts for Weatherford in Congo.  The company also allowed its subsidiary to enter into a joint venture agreement with companies whose beneficial owners included Angolan oil company officials and a relative of an Angolan Minister in order to win business.  A Weatherford employee reported in a 2006 ethics questionnaire that Weatherford personnel were making payments to government officials in Angola and elsewhere, but the company failed to investigate.

The SEC�s complaint also alleges that Weatherford failed to perform due diligence on a distributor suggested by an official at a national oil company in the Middle East.  From 2005 to 2011, Weatherford and its subsidiaries awarded more than $11.8 million in improper �volume discounts� to the distributor � money intended for the creation of a slush fund to pay foreign officials.

According to the SEC�s complaint, the misconduct went beyond the use of agents or other third parties.  Weatherford provided improper travel and entertainment to officials of a state-owned company in Algeria with no legitimate business purpose.  For example, Weatherford paid for a 2006 FIFA World Cup trip by two of the officials, the July 2006 honeymoon of an official�s daughter, and an October 2005 religious trip to Saudi Arabia by an official and his family that was improperly recorded as a donation in Weatherford�s books and records.  Weatherford�s Middle East subsidiary also made more than $1.4 million in improper payments to obtain nine contracts under the Oil-for-Food program in 2002.  Iraqi ministries demanded improper �inland transportation fees� in an effort to subvert the UN program.  Weatherford�s subsidiary complied with the Iraqi demands and paid more than $115,000 in fees despite invoices that included charges inconsistent with the actual deliveries. Weatherford obtained more than $7 million in profits from the misconduct.

The SEC further alleges that managers at Weatherford�s subsidiary in Italy flouted the lack of internal controls and misappropriated more than $200,000 in company funds, some of which was improperly paid to Albanian tax auditors.  The managers misreported cash advances, diverted payments on previously paid invoices, misappropriated government rebate checks, and received reimbursement for such purchases as golf equipment and perfume that did not relate to business activities.

According to the SEC�s complaint, Weatherford employees created false accounting and inventory records from 2002 to 2007 to hide the illegal commercial sales to Cuba, Syria, Sudan, and Iran.  During this time period, exporting or re-exporting goods or services from the U.S. to these sanctioned countries was prohibited.  The falsified financial statements and books and records of Weatherford subsidiaries involved in the misconduct were consolidated into the financial statements of the parent company.

The SEC�s complaint alleges that Weatherford violated the anti-bribery, books and records, and internal accounting controls provisions of the FCPA, specifically Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Securities Exchange Act of 1934.  Weatherford agreed to pay $65,612,360.34 to the SEC in the global settlement, including a $1.875 million penalty assessed in part for lack of cooperation early in the investigation.  Weatherford agreed to pay $87 million in criminal fines to the Department of Justice for the FCPA violations, and $100 million to the other three agencies for the sanctions violations.  The company also must comply with certain undertakings, including the retention of an independent compliance monitor for 18 months and self-reporting to the SEC staff for an additional 18 months.

The SEC�s investigation, which is continuing, has been conducted by Tracy L. Price, Kelly G. Kilroy, and Stanley Cichinski of the FCPA Unit as well as Natalie Lentz and Robert Dodge.  The SEC appreciates the assistance of the Justice Department, Commerce Department, Treasury Department, and U.S. Attorney�s Office in Houston.

Please also feel free to go to the International Whistleblower Reward Information Center for more information on International Bribe Rewards and International Collaborations.

Foreign Corrupt Practices Act Whistleblower Lawyer, International Bribery Whistleblower Reward Lawyer, Foreign Corrupt Practices Act Whistleblower Reward Lawyer,  SEC Bribery Whistleblower Incentive Program Lawyer, & Illegal Bribe Bounty Action Lawyer by International Business Bribery Whistleblower Lawyer and Foreign Corrupt Practices Act Whistleblower Reward Lawyer Jason Coomer

Under the Foreign Corrupt Practices Act and the new SEC Whistleblower Incentive Program, whistleblowers with original and specialized knowledge and evidence of corporate bribery and illegal kickbacks are eligible to recover large economic awards.  By gathering this evidence and going through a lawyer, these whistleblowers can protect their identity through the process and potential collect large rewards of 10% to 30% of the monetary sanctions including disgorged funds.  If you are aware of an illegal bribe or illegal kickback that was used to secure a large contract, please feel free to contact International Business Illegal Kickback and Bribery Whistleblower Lawyer Jason Coomer via e-mail message or use our submission form about a potential SEC Whistleblower Incentive Program Action or other Whistleblower Bounty Action. 

Foreign Corrupt Practices Act Whistleblower Lawyer, International Bribery Whistleblower Reward Lawyer, Foreign Corrupt Practices Act Whistleblower Reward Lawyer,  SEC Bribery Whistleblower Incentive Program Lawyer, & Illegal Bribe Bounty Action Lawyer by International Business Bribery Whistleblower Lawyer and Foreign Corrupt Practices Act Whistleblower Reward Lawyer Jason Coomer

The Foreign Corrupt Practices Act (FCPA) applies to "issuers"� (U.S. and foreign companies listed on U.S. securities exchanges and their employees); "domestic concerns"� which run the gamut of business entities organized under U.S. laws or with their principal place of business in the United States; the officers, directors, employees, and agents of those U.S. business entities (irrespective of nationality); U.S. citizens; U.S. resident aliens; "any person"� including all foreign persons, who commit an act in furtherance of a foreign bribe while in the United States, and U.S. businesses and nationals acting abroad. A Company must require all of its affiliated companies and all of their employees to comply with the Foreign Corrupt Practices Act.

Foreign Corrupt Practices Act (FCPA) Prohibitions

The Foreign Corrupt Practices Act (FCPA) prohibits the offer or making of payments or giving anything of value, either directly or indirectly, to any foreign official, political party or political candidate, or public international organization to obtain or maintain business when the offer, payment or gift is intended to influence a desired action; induce an act in violation of a lawful duty; cause a person to refrain from acting in violation of a lawful duty; secure any improper advantage; or influence the decision of a government or instrumentality.  These prohibitions preclude payments were unlawful under the laws of the country in which payment was made; payments that are not legitimate expenses directly related to the promotion, demonstration or explanation of the company's product or services; and payments that are not made in accordance with a contract between the company and a foreign entity.  These prohibitions also include third party actions where the company knows that a payment or a gift will be provided to a government official or agency for the purpose of obtaining a contract or business. 

Violations of the Foreign Corrupt Practices Act (FCPA) are particularly common when a new market is opening up because of the intense interaction with a foreign government during the opening of the market; in markets that are under heightened government scrutiny or regulation; in markets where foreign investors including U.S. business operate through foreign consultants and contractors; and in markets where foreign companies are acting through  partners in joint ventures.

International businesses and large corporations that are conducting business in a new market which is opening up; in markets that are under heightened government scrutiny or regulation; in markets where foreign investors operate through foreign consultants and contractors; and in markets where foreign companies are acting through  partners in joint ventures should have strong compliance departments and anti bribery policies fail to properly prohibit illegal kickbacks, bribery, and other violations of the Foreign Corrupt Practices Act (FCPA).  These compliance departments and anti bribery policies should including strong and clear policies regarding suppliers in the supply chain and mandate that third party business partners such as agents, distributors and joint venture partners comply with the Foreign Corrupt Practices Act (FCPA). 

Foreign Corporation Illegal Bribe Whistleblower Lawsuit, Domestic Corporation Illegal Kickback Lawsuit, Violations of the Foreign Corrupt Practices Act Whistleblower Lawsuit,  FCPA SEC  Whistleblower Lawsuit, SEC Whistleblower Incentive Program Lawsuit, & Illegal Corporate Bribe Bounty Lawsuit Information

Corporations that pay illegal kickbacks and bribes to government officials and former government officials in exchange for contracts including large building projects can be brought to justice and made to pay large penalties under the Foreign Corrupt Practices Act and whistleblowers that bring these corporations to justice may be able to collect large economic rewards under the  Securities Exchange Act (SEC Whistleblower Bounty Actions) and the Commodity Exchange Act (CFTC Whisteblower Bounty Actions).

The Illegal Bribe Whistleblower or Illegal Kickback Whistleblower may be entitled to not only the amount of the illegal bribe or kickback, but the benefit of the illegal bribe or kickback.  In cases where $100,000.00 bribe is made to obtain a $100 million building project, the Illegal Bribe Whistleblower or Illegal Kickback Whistleblower may be entitled to 10 to 30% of the $100,000,000.00 and the $100,000.00 translating into a $10 million to $30 million award.

International Bribe Lawyer, International Business Illegal Kickback Lawyers, Violations of the Foreign Corrupt Practices Act Lawyers,  FCPA Bounty Lawyers, SEC Whistleblower Incentive Program Lawyers, & Illegal International Business Bribery Informant Bounty Lawyers by International Business Bribe Lawyer and Illegal Kickback Whistleblower Recovery Lawyer Jason Coomer

As an International Business Illegal Bribery Whistleblower Bounty Lawyer and SEC International Business Illegal Kickback Whistleblower Reward Lawyer, Jason S. Coomer commonly works with other powerful illegal international business contract bribe whistleblower lawyers and illegal contract kickback whistleblower award lawyers to handle large International Business Bribery Whistleblower Bounty Lawsuits, SEC International Business Illegal Bribe Whistleblower Reward Lawsuits, International Business Illegal Kickback Whistleblower Bounty Actions, Commodity Fraud Bounty Lawsuits, and other Foreign Corrupt Practices Act Whistleblower Reward Lawsuits.  He also works on Medicare Fraud Whistleblower Lawsuits, Defense Contractor Fraud Whistleblower Lawsuits, Stimulus Fraud Whistleblower Lawsuits, Government Contractor Fraud Whistleblower Lawsuits, Medicare Illegal Kickback Lawsuits, Confidential Financial Analyst Whistleblower Reward Lawsuits and other whistleblower recovery lawsuits.

If you are the original source with special knowledge of fraud and are interested in learning more about an International Business illegal kickback, SEC violation, FCPA violation, or bribe whistleblower recovery lawsuit, please feel free to contact International Business Illegal Kickback and Bribery Whistleblower Lawyer Jason Coomer via e-mail message or use our submission form about a potential SEC Whistleblower Incentive Program Action, Whistleblower Recovery Lawsuit, or other Whistleblower Bounty Action.