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...