In a recently released letter (here), the Justice Department issued a declination to the Insurance Corporation of Barbados Limited (ICBL) for violations of the FCPA under the FCPA Corporate Enforcement Policy.  DOJ required ICBL to pay approximately $93,000 in disgorgement. ICBL paid approximately $36,000 in bribes to Donville Innis, a Barbadian government official, in exchange for government contracts worth approximately $686,000 and $93,000 in profits....