- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2020-04-27T15:46:00
A Brazilian construction company that paid nearly $50 million in kickbacks has been banned from participating in Inter-American Development Bank-funded projects for more than two years.
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Whether you’re a multinational telecommunications company looking to certify your anti-corruption program post-settlement, or a biochemical company victimized by a “rogue” employee, seeing the light at the end of the enforcement tunnel isn’t always easy.
Bank of America avoided a monetary penalty in agreeing to settle charges with the Treasury Department’s Office of the Comptroller of the Currency but was ordered to shore up previously disclosed deficiencies in its Bank Secrecy Act/anti-money laundering (BSA/AML) and sanctions compliance programs.
Aviation maintenance services provider AAR Corp. will pay nearly $56 million to settle charges that it violated the Foreign Corrupt Practices Act when it paid bribes to government officials in Nepal and South Africa.
The United States broke from a three-year downturn in bribery-related enforcement actions, while Brazil continued its emergence in the space, according to the results of the latest annual Global Enforcement Report by nonprofit TRACE.
The number of U.S. foreign bribery enforcement actions slowed notably in 2021, while the overall pace of transnational anti-bribery enforcement actions and investigations lagged worldwide, according to TRACE International’s latest enforcement report.
A payment by a U.S.-based company to a third-party intermediary under circumstances that placed an employee’s life and well-being at “significant risk” would not trigger enforcement under the anti-bribery provisions of the FCPA, the Department of Justice stated in an opinion procedure.
