reinsurance Archives - Corruption, Crime & Compliance

4 Dec, 2023

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...

General

29 Nov, 2023

Lessons Learned from the Tysers Insurance Brokers and H.W. Wood Limited FCPA Settlements (Part III of III)

The Tysers and Wood FCPA settlements reflect something old and something new in the FCPA enforcement world. On the old side, at the core of the FCPA violations was the critical role played by the intermediary company. Unlike most third-party FCPA cases, where a third-party may be enlisted to further a bribery scheme by funneling payments directly to a foreign official, the intermediary in the...