Raytheon’s comprehensive settlement included FCPA violations and failures to make required disclosures to the Defense Department concerning fees and commissions.  This portion of the settlement was filed in the Eastern District of New York. Raytheon formed a joint venture with a French company.  Its bribery scheme involved a subsidiary of the joint venture, Integrated Defense Systems (“IDS”), which was controlled by Raytheon. Between approximately 2012...

Raytheon Company (Raytheon) — a subsidiary of defense contractor, RTX (formerly known as Raytheon Technologies Corporation) — agreed to pay over $950 million to resolve the Justice Department’s investigations into: (i) a major government fraud scheme involving defective pricing on certain government contracts; (ii) violations of the Foreign Corrupt Practices Act (FCPA); and (iii) the Arms Export Control Act (AECA) and its implementing regulations, the International Traffic...

The SEC’s recent settlement with Deere & Company for $9.9 million for FCPA violations is another textbook example of bribery schemes, which revealed the absence of a culture of compliance, and the circumvention of basic entertainment, hospitality and travel expense controls.  Deere’s bribery scheme involved its Thailand subsidiary, Wirtgen Thailand, and various improper payments to government officials, including cash, sham consulting fees, extravagant “factory visit”...

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions — Vitol, Sargeant Marine, Glencore, Freepoint, and Gunvor. DOJ’s corporate resolutions are connected to individual prosecutions and guilty pleas of...

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list of international commodity trading companies to suffer FCPA enforcement actions — Vitol, Sargeant Marine, Glencore, Freepoint, and Gunvor. DOJ’s corporate resolutions are connected to individual prosecutions and guilty pleas of...

The Securities and Exchange Commission has gained well-publicized traction through its formal whistleblower bounty program.  Only a small portion of these whistleblower reports involve FCPA, anti-bribery allegations.  Notwithstanding this fact, the SEC whistleblower program has been an unquestioned success.  Given this example, it is not surprising that the Department of Justice recently announced its plan to create its own whistleblower bounty program. In a recent...