International Bribery Scheme Rewards: International Bribery Scheme Whistleblowers Can Confidentially Expose Large Bribery Schemes and Earn Large Financial Rewards by International Bribery Scheme Whistleblower Reward Lawyer Lawyer Jason Coomer

Large financial rewards are being offered to whistleblowers that confidentially expose large international bribery schemes.  These whistleblowers can work through an international bribery scheme whistleblower reward 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.  If you are aware of a large international bribery scheme or other significant violations of the Foreign Corrupt Practice Act (FCPA), please feel free to contact International Bribery Scheme Whistleblower Reward Lawyer Jason Coomer via e-mail message or use our submission form about a potential SEC Foreign Corrupt Practices Act Whistleblower Bounty Action. 

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.

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 ØKOKRIM, 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.

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 Corrupt Practices Act (FCPA) Exceptions

Under the Foreign Corrupt Practices Act (FCPA), the only exception to the prohibition of making payments to do business in another country are qualified facilitating payments. Qualified facilitating payments made in accordance with local custom or to expedite or secure the performance of routine government action that the payor is entitled to receive, such as government action to obtain licenses or permits, process government papers such as visas and work orders, or obtain government provided services such as police protection, mail, power or phone services may be exempted from coverage by the 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 Business Illegal Bribery Whistleblower Recovery Lawyers, International Business Illegal Kickback Whistleblower Reward Lawyers, Violations of the Foreign Corrupt Practices Act Whistleblower Bounty Lawyers,  FCPA Whistleblower Bounty Lawyers, SEC Whistleblower Incentive Program Lawyers, & Illegal International Business Bribery Informant Bounty Lawyers by International Business Bribery Whistleblower 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.