FROM: U.S. DEPARTMENT OF JUSTICE
Tuesday, July 17, 2012
The Nordam Group Inc. Resolves Foreign Corrupt Practices Act Violations and Agrees to Pay $2 Million Penalty
WASHINGTON – The NORDAM Group Inc., a provider of aircraft maintenance, repair and overhaul (MRO) services based in Tulsa, Okla., has entered into an agreement with the Department of Justice to pay a $2 million penalty to resolve violations of the Foreign Corrupt Practices Act (FCPA), announced Assistant Attorney General Lanny A. Breuer of the Justice Department’s Criminal Division.
According to the agreement, NORDAM, its subsidiaries and affiliates paid bribes to employees of airlines created, controlled and exclusively owned by the People’s Republic of China in order to secure contracts to perform MRO services for those airlines. The bribes were paid both directly and indirectly to the airline employees. In an effort to disguise the bribes, three employees of NORDAM’s affiliate entered into sales representation agreements with fictitious entities and then used the money paid by NORDAM to those entities to pay bribes to the airline employees.
In addition to the monetary penalty, NORDAM agreed to cooperate with the department for the three-year term of the agreement, to report periodically to the department concerning NORDAM’s compliance efforts, and to continue to implement an enhanced compliance program and internal controls designed to prevent and detect FCPA violations.
The department entered into a non-prosecution agreement with NORDAM as a result of NORDAM’s timely, voluntary and complete disclosure of the conduct, its cooperation with the department and its remedial efforts. In addition, the agreement recognizes that a fine below the standard range under the U.S. Sentencing Guidelines is appropriate because NORDAM fully demonstrated to the department, and an independent accounting expert retained by the department verified, that a fine exceeding $2 million would substantially jeopardize the company’s continued viability.
The case is being handled by Trial Attorneys Daniel S. Kahn and Stephen J. Spiegelhalter of the Criminal Division’s Fraud Section. The division’s Office of International Affairs provided assistance. Assistant U.S. Attorney Kevin Leitch from the Northern District of Oklahoma also provided assistance in the case. The case was investigated by the FBI’s Washington Field Office’s team of special agents dedicated to the investigation of foreign bribery cases.
Showing posts with label PAYING BRIBES. Show all posts
Showing posts with label PAYING BRIBES. Show all posts
Tuesday, July 31, 2012
Thursday, September 22, 2011
SAUDI BASED COMPANY AGREES TO PAY $13 MILLION TO SETTLE KICKBACK AND GRATUITIES ALLEGATIONS
The following excerpt is from the Department of Justice website:
Friday, September 16, 2011
“WASHINGTON – Saudi Arabia-based Tamimi Global Company Ltd (TAFGA) has agreed to pay the United States $13 million to resolve criminal and civil allegations that the company paid kickbacks to a Kellogg Brown & Root Inc. (KBR) employee and illegal gratuities to a former U.S. Army sergeant, in connection with contracts in support of the Army’s operations in Iraq and Kuwait. The civil matter was handled by the Justice Department’s Civil Division, and the criminal matter was handled by the U.S. Attorney’s Office for the Central District of Illinois.
The U.S. alleges that employees of TAFGA paid kickbacks to KBR to obtain subcontracts awarded under LOGCAP (Logistics Civil Augmentation Program) III – KBR’s prime contract with the U.S. Army to provide logistical support to the military in conflicts abroad, including Iraq and Afghanistan. LOGCAP III is the third generation of contracts under the program. KBR performs its obligations under the contract largely through subcontractors such as TAFGA.
The U.S. also alleges that employees of TAFGA paid illegal gratuities to Army Sergeant Ray Chase. Chase was responsible for Army food services at camps Doha and Arifjan (Zone 1) in Kuwait in 2002 and 2003. As alleged in the information, Chase received regular payments from TAFGA employees on account of official acts that he took while he served in Kuwait in 2002 and 2003. TAFGA has now admitted that its employees entered into a conspiracy to pay illegal gratuities to Chase.
TAFGA appeared today before Senior Judge Michael M. Mihm in the U.S. District Court for the Central District of Illinois in Peoria, Ill., on consideration of a deferred prosecution agreement (DPA) between TAFGA and the U.S. Attorney’s Office. Under the terms of that agreement, TAFGA will pay the United States $5.6 million as part of a deferred prosecution and institute a strict compliance program to ensure that the company and its employees will abide by the legal and ethical standards required for government contracts. If TAFGA meets its obligations under the agreement without violation for 18 months, the United States will dismiss the criminal charges.
As part of the criminal agreement, TAFGA admitted conspiring to pay kickbacks to former KBR subcontract manager Steven Lowell Seamans in return for favorable treatment in the award and performance of a subcontract to provide dining services at Camp Arifjan in Kuwait. The conspiracy lasted from October 2002 to March 2006. In related proceedings in March 2006, Seamans pleaded guilty to accepting $60,500 in kickbacks from TAFGA’s former director of operations in Kuwait, Mohammad Shabbir Khan, for the award of the Camp Arifjan subcontract. In June 2006, Khan pleaded guilty to paying Seamans $133,000 in kickbacks for the award of this and another subcontract. Both were sentenced to prison and ordered to pay restitution. In the DPA unsealed today, TAFGA also admitted that as part of the conspiracy charged its then employees made false statements to federal investigators about a phantom business deal to cover up wire transfers to Seamans transmitting the kickbacks. As alleged, this transaction also involved another former TAFGA operations director, Zubair Khan. Khan has been indicted in the Central District of Illinois, and that case is still pending.
With respect to the conspiracy involving Chase, TAFGA admitted that it is responsible for the misconduct of its employees who agreed to provide Chase illegal gratuities and in furtherance of that conspiracy provided Chase money and use of an apartment in Kuwait. All of these illegal gratuities were paid to Chase on account of official acts he performed, or was going to perform, at Camps Doha and Arifjan in Kuwait in relation to the war effort. In 2010, Chase pled guilty and was sentenced to prison for accepting approximately $1.4 million in illegal gratuities from various contractors, including TAFGA. Chase was prosecuted in the Central District of Illinois.
In a separate civil settlement agreement, TAFGA agreed to pay the United States an additional $7.4 million to resolve civil allegations that TAFGA paid kickbacks in return for favorable treatment in the award and performance of the Camp Arifjan subcontract, a subcontract for dining facilities at the Baghdad Palace in Iraq, and five smaller subcontracts for dining services and other logistical support in Iraq, including temporary personal services and installation of tent pads and a shower/laundry unit. The United States alleged that TAFGA’s conduct violated the False Claims Act and the Anti-Kickback Act.
“Kickbacks and collusion in military contracting corrode the process of supplying our men and women in uniform with the quality supplies they need and deserve,” said Tony West, Assistant Attorney General for the Justice Department’s Civil Division. “When we believe companies are engaging in wartime profiteering, we will not hesitate to act.”
TAFGA is the 13th defendant criminally charged by the LOGCAP Working Group, based in the Central District of Illinois and led by the U.S. Attorney’s Office. This district is also home to the Rock Island Arsenal in Rock Island, Ill., where LOGCAP III is administered by the Army Sustainment Command, giving the district jurisdiction over these cases.
“Our district was one of the first in the country to take on the challenge of prosecuting war zone cases involving fraud, bribes, and kickbacks that took place during the military conflict in Southwest Asia,” said U.S. Attorney Jim Lewis, Central District of Illinois. “Our commitment to prosecute these cases is rivaled only by our commitment to the men and women who serve in our armed forces. The agreements announced today will return $13 million to the American taxpayer and serve as an example of our long-term commitment to root out public corruption in every form, especially corruption perpetrated in war zones.”
The compliance program agreed to under the deferred prosecution agreement requires TAFGA to establish a new Kuwait management team as well as an ethics and compliance team with oversight over U.S. government contracts and subcontracts, to strengthen its code of business conduct, to modernize its standard operating procedures for financial and accounting functions, to institute a compliance hotline, and to retain a contract and compliance consultant to evaluate and monitor its compliance program.
These settlements are a direct result of the efforts of the interagency Financial Fraud Enforcement Task Force. The task force was established to wage an aggressive, coordinated and proactive effort to investigate and prosecute financial crimes. It includes representatives from a broad range of federal agencies, including regulatory authorities, inspectors general, and state and local law enforcement who, working together, bring to bear a powerful array of criminal and civil enforcement resources. The task force is working to improve efforts across the federal executive branch and, with state and local partners, investigate and prosecute significant financial crimes, ensure just and effective punishment for those who perpetrate financial crimes, combat discrimination in the lending and financial markets, and recover proceeds for victims of financial crimes.
The criminal case was prosecuted by Assistant U.S. Attorney Matthew J. Cannon and former Assistant U.S. Attorney Jeffrey B. Lang, the current and former lead prosecutors for the LOGCAP Working Group. Former Department of Justice Senior Trial Attorney Joseph Capone in the Fraud Section of the Criminal Division also worked on the case. The civil case was prosecuted by Assistant Director Judith Rabinowitz, Senior Trial Counsel John A. Kolar and Trial Attorney Kelley C. Hauser in the Justice Department’s Commercial Litigation Branch of the Civil Division.
Investigative agencies that participated in the investigations include the Internal Revenue Service Criminal Investigation Division, Chicago Field Office; the Defense Criminal Investigative Service, Central Field Office, Rock Island Post of Duty; U.S. Army Criminal Investigation Command, Major Procurement Fraud Unit, located at Rock Island Arsenal and the FBI, Springfield Division.”
The following excerpt is from the Department of Justice website:
Friday, September 16, 2011
“WASHINGTON – Saudi Arabia-based Tamimi Global Company Ltd (TAFGA) has agreed to pay the United States $13 million to resolve criminal and civil allegations that the company paid kickbacks to a Kellogg Brown & Root Inc. (KBR) employee and illegal gratuities to a former U.S. Army sergeant, in connection with contracts in support of the Army’s operations in Iraq and Kuwait. The civil matter was handled by the Justice Department’s Civil Division, and the criminal matter was handled by the U.S. Attorney’s Office for the Central District of Illinois.
The U.S. alleges that employees of TAFGA paid kickbacks to KBR to obtain subcontracts awarded under LOGCAP (Logistics Civil Augmentation Program) III – KBR’s prime contract with the U.S. Army to provide logistical support to the military in conflicts abroad, including Iraq and Afghanistan. LOGCAP III is the third generation of contracts under the program. KBR performs its obligations under the contract largely through subcontractors such as TAFGA.
The U.S. also alleges that employees of TAFGA paid illegal gratuities to Army Sergeant Ray Chase. Chase was responsible for Army food services at camps Doha and Arifjan (Zone 1) in Kuwait in 2002 and 2003. As alleged in the information, Chase received regular payments from TAFGA employees on account of official acts that he took while he served in Kuwait in 2002 and 2003. TAFGA has now admitted that its employees entered into a conspiracy to pay illegal gratuities to Chase.
TAFGA appeared today before Senior Judge Michael M. Mihm in the U.S. District Court for the Central District of Illinois in Peoria, Ill., on consideration of a deferred prosecution agreement (DPA) between TAFGA and the U.S. Attorney’s Office. Under the terms of that agreement, TAFGA will pay the United States $5.6 million as part of a deferred prosecution and institute a strict compliance program to ensure that the company and its employees will abide by the legal and ethical standards required for government contracts. If TAFGA meets its obligations under the agreement without violation for 18 months, the United States will dismiss the criminal charges.
As part of the criminal agreement, TAFGA admitted conspiring to pay kickbacks to former KBR subcontract manager Steven Lowell Seamans in return for favorable treatment in the award and performance of a subcontract to provide dining services at Camp Arifjan in Kuwait. The conspiracy lasted from October 2002 to March 2006. In related proceedings in March 2006, Seamans pleaded guilty to accepting $60,500 in kickbacks from TAFGA’s former director of operations in Kuwait, Mohammad Shabbir Khan, for the award of the Camp Arifjan subcontract. In June 2006, Khan pleaded guilty to paying Seamans $133,000 in kickbacks for the award of this and another subcontract. Both were sentenced to prison and ordered to pay restitution. In the DPA unsealed today, TAFGA also admitted that as part of the conspiracy charged its then employees made false statements to federal investigators about a phantom business deal to cover up wire transfers to Seamans transmitting the kickbacks. As alleged, this transaction also involved another former TAFGA operations director, Zubair Khan. Khan has been indicted in the Central District of Illinois, and that case is still pending.
With respect to the conspiracy involving Chase, TAFGA admitted that it is responsible for the misconduct of its employees who agreed to provide Chase illegal gratuities and in furtherance of that conspiracy provided Chase money and use of an apartment in Kuwait. All of these illegal gratuities were paid to Chase on account of official acts he performed, or was going to perform, at Camps Doha and Arifjan in Kuwait in relation to the war effort. In 2010, Chase pled guilty and was sentenced to prison for accepting approximately $1.4 million in illegal gratuities from various contractors, including TAFGA. Chase was prosecuted in the Central District of Illinois.
In a separate civil settlement agreement, TAFGA agreed to pay the United States an additional $7.4 million to resolve civil allegations that TAFGA paid kickbacks in return for favorable treatment in the award and performance of the Camp Arifjan subcontract, a subcontract for dining facilities at the Baghdad Palace in Iraq, and five smaller subcontracts for dining services and other logistical support in Iraq, including temporary personal services and installation of tent pads and a shower/laundry unit. The United States alleged that TAFGA’s conduct violated the False Claims Act and the Anti-Kickback Act.
“Kickbacks and collusion in military contracting corrode the process of supplying our men and women in uniform with the quality supplies they need and deserve,” said Tony West, Assistant Attorney General for the Justice Department’s Civil Division. “When we believe companies are engaging in wartime profiteering, we will not hesitate to act.”
TAFGA is the 13th defendant criminally charged by the LOGCAP Working Group, based in the Central District of Illinois and led by the U.S. Attorney’s Office. This district is also home to the Rock Island Arsenal in Rock Island, Ill., where LOGCAP III is administered by the Army Sustainment Command, giving the district jurisdiction over these cases.
“Our district was one of the first in the country to take on the challenge of prosecuting war zone cases involving fraud, bribes, and kickbacks that took place during the military conflict in Southwest Asia,” said U.S. Attorney Jim Lewis, Central District of Illinois. “Our commitment to prosecute these cases is rivaled only by our commitment to the men and women who serve in our armed forces. The agreements announced today will return $13 million to the American taxpayer and serve as an example of our long-term commitment to root out public corruption in every form, especially corruption perpetrated in war zones.”
The compliance program agreed to under the deferred prosecution agreement requires TAFGA to establish a new Kuwait management team as well as an ethics and compliance team with oversight over U.S. government contracts and subcontracts, to strengthen its code of business conduct, to modernize its standard operating procedures for financial and accounting functions, to institute a compliance hotline, and to retain a contract and compliance consultant to evaluate and monitor its compliance program.
These settlements are a direct result of the efforts of the interagency Financial Fraud Enforcement Task Force. The task force was established to wage an aggressive, coordinated and proactive effort to investigate and prosecute financial crimes. It includes representatives from a broad range of federal agencies, including regulatory authorities, inspectors general, and state and local law enforcement who, working together, bring to bear a powerful array of criminal and civil enforcement resources. The task force is working to improve efforts across the federal executive branch and, with state and local partners, investigate and prosecute significant financial crimes, ensure just and effective punishment for those who perpetrate financial crimes, combat discrimination in the lending and financial markets, and recover proceeds for victims of financial crimes.
The criminal case was prosecuted by Assistant U.S. Attorney Matthew J. Cannon and former Assistant U.S. Attorney Jeffrey B. Lang, the current and former lead prosecutors for the LOGCAP Working Group. Former Department of Justice Senior Trial Attorney Joseph Capone in the Fraud Section of the Criminal Division also worked on the case. The civil case was prosecuted by Assistant Director Judith Rabinowitz, Senior Trial Counsel John A. Kolar and Trial Attorney Kelley C. Hauser in the Justice Department’s Commercial Litigation Branch of the Civil Division.
Investigative agencies that participated in the investigations include the Internal Revenue Service Criminal Investigation Division, Chicago Field Office; the Defense Criminal Investigative Service, Central Field Office, Rock Island Post of Duty; U.S. Army Criminal Investigation Command, Major Procurement Fraud Unit, located at Rock Island Arsenal and the FBI, Springfield Division.”
Thursday, September 15, 2011
BRIDGESTONE CORPORATION TO PAY $28 MILLION FOR BID RIGGING AND BRIBERY CONSPIRACIES
The following excerpt is from the Department of Justice website:
THURSDAY, SEPTEMBER 15, 2011
“WASHINGTON — Bridgestone Corporation has agreed to plead guilty and to pay a $28 million criminal fine for its role in conspiracies to rig bids and to make corrupt payments to foreign government officials in Latin America related to the sale of marine hose and other industrial products manufactured by the company and sold throughout the world, announced Acting Assistant Attorney General Sharis A. Pozen of the Department of Justice’s Antitrust Division and Assistant Attorney General Lanny A. Breuer of the Department of Justice’s Criminal Division.
A two-count criminal information was filed today in U.S. District Court in Houston against Bridgestone, a Tokyo-headquartered manufacturer of marine hose and other industrial products, charging the company with conspiring to violate the Sherman Act and the Foreign Corrupt Practices Act (FCPA). According to the court document, Bridgestone conspired to rig bids, fix prices and allocate market shares of marine hose in the United States and elsewhere and, separately, conspired to make corrupt payments to government officials in various Latin American countries to obtain and retain business. The department said Bridgestone participated in the conspiracies from as early as January 1999, and continuing until as late as May 2007.
Under the terms of the plea agreement, which is subject to court approval, Bridgestone has also agreed to cooperate fully in the department’s ongoing investigations.
Marine hose is a flexible rubber hose used to transfer oil between tankers and storage facilities. During the bid rigging conspiracy, according to the court document, the cartel affected prices for hundreds of millions of dollars worth of marine hose and related products sold worldwide.
According to the antitrust charge, Bridgestone and its co-conspirators agreed to allocate shares of the marine hose market and to use a price list for marine hose in order to implement the conspiracy. Bridgestone and its co-conspirators agreed not to compete for one another’s customers either by not submitting prices or bids, or by submitting intentionally high prices or bids to certain customers. As part of the conspiracy, Bridgestone and its co-conspirators provided information received from customers in the United States and elsewhere about upcoming marine hose jobs to a co-conspirator who served as the coordinator of the conspiracy. Bridgestone received marine hose prices for customers in the United States and elsewhere from the coordinator of the conspiracy and then sold the marine hose to those customers at collusive and noncompetitive prices and then concealed the conspiracy through various means, including code names, private email accounts and telephone numbers.
The department also charged that, in order to secure sales of marine hose in Latin America, Bridgestone authorized and approved corrupt payments to foreign government officials employed at state-owned entities. Bridgestone’s local sales agents agreed to pay employees of state-owned customers a percentage of the total value of proposed sales. When Bridgestone secured a sale, it would pay the local sales agent a “commission” consisting of not only the local sales agent’s actual commission but also the corrupt payments to be made to employees of the state-owned customer. The local sales agent then was responsible for passing the agreed-upon corrupt payment to the employees of the customer.
Bridgestone is the fifth company to be charged in the Antitrust Division’s bid rigging investigation. To date, nine individuals have been convicted and sentenced to a total of 4,557 days in prison for their involvement in the marine hose conspiracy, including Misao Hioki, the former general manager of Bridgestone’s international engineered products department, who was sentenced to two years in prison on Dec. 10, 2008. Hioki also pleaded guilty and was sentenced for his role in the FCPA conspiracy.
Bridgestone is charged with conspiring to violate the Sherman Act, which carries a maximum $100 million criminal fine for corporations. Bridgestone is also charged with conspiring to violate the FCPA, which carries a maximum $500,000 fine for corporations. The maximum fine for each count may be increased to twice the gain derived from the crime or twice the loss suffered by the victims of the crime, if either of those amounts is greater than the statutory maximum fine.
Under the plea agreement, the department recognized Bridgestone’s cooperation with the investigations, including conducting a worldwide internal investigation, voluntarily making employees available for interviews, and collecting, analyzing and providing to the department voluminous evidence and information. In addition, the plea agreement acknowledges Bridgestone’s extensive remediation, including restructuring the relevant part of its business, terminating many of its third-party agents and taking remedial actions with respect to employees responsible for many of the corrupt payments. Under the terms of the plea agreement, Bridgestone has committed to continuing to enhance its compliance program and internal controls. As a result of these mitigating factors, the department agreed to recommend a substantially reduced fine.
This case is being prosecuted by the Antitrust Division’s National Criminal Enforcement Section and the Criminal Division’s Fraud Section. In addition to the Antitrust and Criminal Divisions, the ongoing investigation is being conducted by the Defense Criminal Investigative Service (DCIS) of the Department of Defense’s Office of Inspector General, the U.S. Navy Criminal Investigative Service and the FBI. Law enforcement agencies from multiple foreign jurisdictions are also investigating or assisting in the ongoing matter.“
THURSDAY, SEPTEMBER 15, 2011
“WASHINGTON — Bridgestone Corporation has agreed to plead guilty and to pay a $28 million criminal fine for its role in conspiracies to rig bids and to make corrupt payments to foreign government officials in Latin America related to the sale of marine hose and other industrial products manufactured by the company and sold throughout the world, announced Acting Assistant Attorney General Sharis A. Pozen of the Department of Justice’s Antitrust Division and Assistant Attorney General Lanny A. Breuer of the Department of Justice’s Criminal Division.
A two-count criminal information was filed today in U.S. District Court in Houston against Bridgestone, a Tokyo-headquartered manufacturer of marine hose and other industrial products, charging the company with conspiring to violate the Sherman Act and the Foreign Corrupt Practices Act (FCPA). According to the court document, Bridgestone conspired to rig bids, fix prices and allocate market shares of marine hose in the United States and elsewhere and, separately, conspired to make corrupt payments to government officials in various Latin American countries to obtain and retain business. The department said Bridgestone participated in the conspiracies from as early as January 1999, and continuing until as late as May 2007.
Under the terms of the plea agreement, which is subject to court approval, Bridgestone has also agreed to cooperate fully in the department’s ongoing investigations.
Marine hose is a flexible rubber hose used to transfer oil between tankers and storage facilities. During the bid rigging conspiracy, according to the court document, the cartel affected prices for hundreds of millions of dollars worth of marine hose and related products sold worldwide.
According to the antitrust charge, Bridgestone and its co-conspirators agreed to allocate shares of the marine hose market and to use a price list for marine hose in order to implement the conspiracy. Bridgestone and its co-conspirators agreed not to compete for one another’s customers either by not submitting prices or bids, or by submitting intentionally high prices or bids to certain customers. As part of the conspiracy, Bridgestone and its co-conspirators provided information received from customers in the United States and elsewhere about upcoming marine hose jobs to a co-conspirator who served as the coordinator of the conspiracy. Bridgestone received marine hose prices for customers in the United States and elsewhere from the coordinator of the conspiracy and then sold the marine hose to those customers at collusive and noncompetitive prices and then concealed the conspiracy through various means, including code names, private email accounts and telephone numbers.
The department also charged that, in order to secure sales of marine hose in Latin America, Bridgestone authorized and approved corrupt payments to foreign government officials employed at state-owned entities. Bridgestone’s local sales agents agreed to pay employees of state-owned customers a percentage of the total value of proposed sales. When Bridgestone secured a sale, it would pay the local sales agent a “commission” consisting of not only the local sales agent’s actual commission but also the corrupt payments to be made to employees of the state-owned customer. The local sales agent then was responsible for passing the agreed-upon corrupt payment to the employees of the customer.
Bridgestone is the fifth company to be charged in the Antitrust Division’s bid rigging investigation. To date, nine individuals have been convicted and sentenced to a total of 4,557 days in prison for their involvement in the marine hose conspiracy, including Misao Hioki, the former general manager of Bridgestone’s international engineered products department, who was sentenced to two years in prison on Dec. 10, 2008. Hioki also pleaded guilty and was sentenced for his role in the FCPA conspiracy.
Bridgestone is charged with conspiring to violate the Sherman Act, which carries a maximum $100 million criminal fine for corporations. Bridgestone is also charged with conspiring to violate the FCPA, which carries a maximum $500,000 fine for corporations. The maximum fine for each count may be increased to twice the gain derived from the crime or twice the loss suffered by the victims of the crime, if either of those amounts is greater than the statutory maximum fine.
Under the plea agreement, the department recognized Bridgestone’s cooperation with the investigations, including conducting a worldwide internal investigation, voluntarily making employees available for interviews, and collecting, analyzing and providing to the department voluminous evidence and information. In addition, the plea agreement acknowledges Bridgestone’s extensive remediation, including restructuring the relevant part of its business, terminating many of its third-party agents and taking remedial actions with respect to employees responsible for many of the corrupt payments. Under the terms of the plea agreement, Bridgestone has committed to continuing to enhance its compliance program and internal controls. As a result of these mitigating factors, the department agreed to recommend a substantially reduced fine.
This case is being prosecuted by the Antitrust Division’s National Criminal Enforcement Section and the Criminal Division’s Fraud Section. In addition to the Antitrust and Criminal Divisions, the ongoing investigation is being conducted by the Defense Criminal Investigative Service (DCIS) of the Department of Defense’s Office of Inspector General, the U.S. Navy Criminal Investigative Service and the FBI. Law enforcement agencies from multiple foreign jurisdictions are also investigating or assisting in the ongoing matter.“
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