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Episode 300 — Deep Dive into DOJ FCPA Settlement with Two U.K. Reinsurance Companies for Bribery in Ecuador

DOJ announced settlements with two U.K.-based reinsurance brokers, H.W. Wood Limited (“Wood”) and Tysers Insurance Brokers (“Tysers”) for their participation in a bribery scheme involving Seguros Sucre S.A. (“Sucre”) and Seguros Rocafuerte S.A. (“Rocafuerte”), two state-owned insurance companies in Ecuador.  Wood and Tysers each entered into a three-year deferred prosecution agreement with DOJ and agreed to the filing of a criminal information in the Southern District of Florida. 

As part of the settlements, Tysers agreed to pay a fine of $36 million and to forfeit $10.5 million, while Wood successfully argued that it was unable to pay the mandated fine of $22.5 million and to forfeit $2.3 million; instead, DOJ imposed against Wood a fine of only $508,000.

According to DOJ, Tysers and Wood paid $2.8 million in bribes to two executives of Ecuadorian state-owned insurance companies Sucre and Rocafuerte as well as other company’s executives. Both bribery schemes were orchestrated to secure business with Sucre and Rocafuerte.  To secure these opportunities, Tysers and Wood enlisted the assistance of a third-party intermediary — Tysers paid $20.3 million and Wood paid $7.9 million in commissions to make the illegal payments.

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