Jenner & Block

Client Alert: Key Lessons from the Seven FCPA Plea Agreements and Indictments Announced Last Week

Last week, the Department of Justice (DOJ) announced a combination of charges and guilty pleas involving seven individuals relating to violations of the Foreign Corrupt Practices Act’s anti-bribery provisions.  On Thursday November 9, 2017, two former oil services executives pleaded guilty to criminal informations in connection with bribery schemes involving officials of the Brazilian state-owned oil company Petrobras as well as other state-owned oil companies in Angola and Equatorial Guinea.  Earlier the same week, on November 7, 2017, court documents were unsealed in Ohio federal court revealing charges against five individuals – four of whom had already pleaded guilty – for allegedly violating the FCPA by paying bribes to foreign officials on behalf of Rolls-Royce.   The four individuals associated with Rolls-Royce had pleaded guilty on December 20, 2016; June 6, 2017; June 13, 2017; and July 28, 2017, and the indictment against the fifth individual had been filed on October 12, 2017.  But the plea agreements and indictment had been kept under seal until last week.

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