Top Ten International Anti-Corruption Developments For December 2017

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary resources. This month we ask: What was the last corporate FCPA enforcement action of 2017? How did the first FIFA jury trial end? What anti-corruption policy statements were made by the United States, the United Kingdom, and the People's Republic of China? The answers to these questions and more are here in our December 2017 Top Ten list.

1. Singapore-Based Oil Rig Builder Resolves Brazilian Bribery Allegations. On December 22, 2017, the U.S. Department of Justice ( DOJ) announced that Keppel Offshore & Marine Ltd. and its U.S. subsidiary, Keppel Offshore & Marine USA Inc., had agreed to resolve allegations that they had paid over $55 million in bribes to Brazilian officials between 2001 and 2014 in order to win 13 contracts with Petrobras, Brazil's state-owned oil company, and another Brazilian entity. According to the allegations, the bribes were paid to an intermediary consulting company that made payments for the benefit of the Brazilian officials and the Brazilian political party. The parent company entered into a deferred prosecution agreement (DPA) with DOJ, while the U.S. subsidiary agreed to plead guilty to conspiring to violate the FCPA's anti-bribery provisions. DOJ also announced that the resolution had been coordinated with Singaporean and Brazilian authorities, for a total combined penalty of $422 million. This is the first coordinated FCPA resolution with Singapore and the most recent of several coordinated resolutions with Brazil.

2. Former Aerospace Executive Pleads Guilty to FCPA Charges. On December 21, 2017, Colin Steven, a former vice president of sales for the Brazilian aerospace company Embraer, pled guilty to charges that he participated in a scheme to pay $1.5 million in bribes to an official at Saudi Aramco, Saudi Arabia's state-owned oil company. Steven, a U.K. citizen residing in the U.A.E., admitted that he engaged in a scheme to pay bribes to a foreign official in exchange for assistance in getting an aircraft sales contract. Steven also admitted that he retained a kickback as part of the scheme and lied to law enforcement about the kickback. The guilty plea follows the execution of an October 2016 DPA between DOJ and Embraer, under which the company agreed to pay $107 million in penalties to DOJ...