Tagged: Airbus bribery

2020 Year in Review: Interesting Enforcement Actions (Part III of IV)

2020 Year in Review: Interesting Enforcement Actions (Part III of IV)

DOJ and the SEC each had a great year in FCPA enforcement.  But it is important to acknowledge that the blockbuster case, Goldman Sachs, was the driver of this successful year.  Goldman Sachs Goldman Sachs paid DOJ and the SEC nearly $4 billion in fines and disgorgement.  DOJ has reccivered nearly $1` billion in assets through its forfeiture initiative. Goldman Sachs was a massive and...

Airbus FCPA Settlement: Review of Airbus Bribery Scheme (Part II of IV)

Airbus FCPA Settlement: Review of Airbus Bribery Scheme (Part II of IV)

Almost every FCPA enforcement action contains important lessons learned in unraveling a bribery scheme.  Airbus has three broad divisions: (1) Commercial Division; (2) Defense & Space Division; and (3) Helicopters Division. The bribery scheme involved China, three Chinese government entities (GE-1, GE-2, and GE-3), and three consultants: Consultant 1, an agent who received payments from Airbus during 2013 to 2015 that were intended for bribes...