Category: Bribery

TIGO Guatemala Pays Over $118 Million to Close U.S. Bribery Case

Key Takeaways$118 Million Resolution: TIGO Guatemala paid more than $118 million to resolve a U.S. investigation into foreign bribery under the FCPA.Two-Year DPA: The company entered a deferred prosecution agreement after being charged with conspiracy to violate U.S. anti-bribery laws.Years-Long Bribery Scheme: From 2012 to 2018, cash bribes were paid to Guatemalan lawmakers and their security teams, some funded with narcotrafficking proceeds.Partial Cooperation Credit: Early disclosure helped, but obstruction by a former shareholder and new evidence later uncovered meant the company did not qualify for full voluntary disclosure benefits.Major Compliance Overhaul: Following Millicom’s takeover, TIGO Guatemala implemented extensive remediation and…

SFO & Five Eyes Publish New Guidance on Indicators of Foreign Bribery

Key TakeawaysJoint Enforcement Signal: The UK Serious Fraud Office and Five Eyes partners have published their first agreed set of foreign bribery indicators, reflecting shared investigative experience across jurisdictions.Early Risk Detection Tool: The guidance is designed to help businesses, compliance teams, and professionals spot patterns that may indicate bribery risk before misconduct escalates.Context Matters: Individual indicators do not imply criminal activity on their own; risk emerges when multiple factors appear together or conflict with a company’s broader risk profile.Overlap With Financial Crime: Several indicators mirror red flags seen in money laundering cases, reinforcing the need for integrated financial crime and…

First Trust Portfolios Fined $10 Million Over Improper Gifts & Misleading Records

First Trust Portfolios has agreed to pay a $10 million fine and accept a censure after the Financial Industry Regulatory Authority (FINRA) found the firm provided lavish gifts and entertainment to broker-dealer representatives in violation of longstanding limits on non-cash compensation tied to investment product sales. The settlement is outlined in a Letter of Acceptance, Waiver and Consent (AWC) that First Trust submitted without admitting or denying the findings. The Illinois-based firm, a wholesale distributor of investment company securities, has been a FINRA member since 1991 and works with hundreds of registered representatives across the country. According to FINRA, from…

Turkish Prosecutors Seek Over 2,000 Years for Incarcerated Istanbul Mayor

Turkish prosecutors accused Istanbul Mayor Ekrem İmamoğlu, who has been incarcerated since March, of 143 corruption and organized crime offenses, including bribery, money laundering, and fraud against public institutions, according to the state-owned Anadolu Agency. If convicted, he could face 849 to 2,430 years in prison. Istanbul Chief Prosecutor Akin Gurlek told media that the indictment is complete and a lawsuit has been filed with the Istanbul High Criminal Court. The case names 402 suspects, including 105 individuals and İmamoğlu himself, who are already in detention. The indictment described İmamoğlu as heading a crime network likened to “the tentacles of…

Spanish court orders ex-UN official extradited to US in bribery case

MADRID (Reuters) -Spain’s High Court has ordered that former senior U.N. official Vitaly Vanshelboim be extradited to the United States where he is accused of taking bribes and money laundering, according to a court document seen by Reuters on Tuesday. Vanshelboim, a Ukrainian national, served in high-ranking roles within the U.N. Office for Project Services (UNOPS) until he was placed on administrative leave in 2021 and subsequently dismissed in 2023. He was arrested in Spain in March on an international warrant issued by the Southern District Court of New York. Vanshelboim is accused of accepting at least $2 million in…

Azerbaijan’s Former Presidential Chief of Staff Placed Under House Arrest

A former chief of staff to the Azerbaijani president has been placed under house arrest on charges of treason, attempting to overthrow the state by force, and money laundering, according to reports circulating in pro-government media outlets. On Tuesday, a Baku court ordered four months of home detention for Ramiz Mehdiyev, 87, citing his advanced age, Qafqazinfo reported. The charges carry a maximum sentence of life imprisonment under Azerbaijan’s criminal code. In a brief phone interview published by Qafqazinfo, Mehdiyev ended the call when asked about the charges. Often dubbed the “grey cardinal” by local media, Mehdiyev wielded considerable influence…

Disgraced former Sen. Bob Menendez’s wife gets 4½ years in prison for her role in a bribery scheme

Former U.S. Sen. Bob Menendez’s wife told a judge that her husband was “not the man I thought he was” before she was sentenced Thursday to 4½ years in prison for selling the powerful New Jersey politician’s influence in exchange for bribes of cash, gold bars and a luxury car. U.S. District Judge Sidney H. Stein sentenced Nadine Menendez, 58, after she was convicted in April of colluding from 2018 to 2023 with her husband, the former Democratic chairman of the Senate Foreign Relations Committee, in a variety of corrupt schemes, some involving assisting the Egyptian government. Sobbing as she…

Former CEO of Dutch ‘Jumbo’ Supermarkets Requests Appeal for Bribery Conviction

Frits van Eerd, former CEO of the Dutch supermarket chain Jumbo, has filed an appeal against his two-year prison sentence on charges including money laundering and accepting bribes, according to his lawyer. The Northern Netherlands District Court in the city of Groningen sentenced van Eerd on August 7, noting that authorities had found 427,607 euros ($498,004) of “criminal money” in his home. Van Eerd also took bribes from a co-defendant in the case, the court ruled. “Look, he has always said, ‘I didn’t do this, I wasn’t bribed.’ And, by the way, the co-defendant says he didn’t bribe anyone. So…

Justice Department Resumes Foreign-Bribery Investigations with Focus on U.S. Competitiveness & National Security

The U.S. Department of Justice (DOJ) just announced that it will resume its foreign-bribery investigations, but with a narrowed focus aimed at protecting American businesses’ ability to compete on the global stage and safeguarding national security. This decision follows a four-month review prompted by an executive order from President Trump, which had paused such investigations earlier this year. Deputy Attorney General Todd Blanche made the announcement, according to the Wall Street Journal, revealing that nearly half of the ongoing Foreign Corrupt Practices Act (FCPA) cases would be closed to align with new enforcement guidelines. Under the revamped framework, investigations will…

Cypriot Auditor Scrutinizes Political Donations From ‘Golden Passport’ Program

Cypriot political parties received more than 1 million euros in donations connected to the country’s controversial “golden passport” program, according to the country’s Auditor General. Before the Cyprus Investment Program was shut down amid allegations of corruption, foreigners could obtain citizenship by purchasing real estate worth at least 2 million euros. The scheme reportedly brought an estimated 9 billion euros into the country over the course of 13 years. The Auditor General published its series of reports on Tuesday — one overview and eight more scrutinizing donations to specific political parties. The reports analyzed a total of 1.12 million euros…

Former German MP Affirms Indictment Accusing Him of Taking Bribes from Azerbaijan

Former conservative parliamentarian Eduard Lintner has affirmed that the indictment against him in the Azerbaijani Laundromat trial is correct — even though it includes accusations that he accepted bribes. While Lintner said in a Munich court on May 15 that he agreed with the indictment, he later told DPA he was innocent, because he did not consider the payments he received from the Azerbaijan government as bribes. The case centers on Azerbaijan’s covert strategy to buy political influence in Europe, particularly within the Parliamentary Assembly of the Council of Europe, a body tasked with safeguarding human rights. The Azerbaijani Laundromat…

California Attorney General Reminds Businesses That Bribery Is Still Illegal, No Matter What’s Happening in Washington

Key Takeaways Bribery is still illegal: Even though the DOJ has paused enforcement, both the FCPA and California law remain in full effect.California has its own enforcement power: The UCL allows the state to take action against businesses for bribery, regardless of what happens on the federal level.No relaxation in compliance: Companies must continue adhering to strong anti-corruption measures to avoid legal risks down the road.Internal controls are key: Businesses should maintain accurate financial records and strong internal controls to keep things above board.Deep Dive California and U.S. businesses should take note, bribing foreign officials is still a big no-no,…

Ex-Senior Chinese Anti-Corruption Official Arrested on Bribery Charges

Li Gang, a former top Chinese anti-corruption official, has been arrested for allegedly accepting bribes, marking a dramatic fall from grace for the former Party watchdog. Banner: EditQ/Wikimedia CommonsRELATED ARTICLES US Lawmakers Pass Megobari Act Targeting Threats to Georgia’s DemocracyOfficials with the ruling Georgian Dream party rejected the move, with the mayor of Tbilisi claiming it was a “deep state” plot. US Sanctions Myanmar Militia Tied to Cyber-Scams, Human TraffickingThe Treasury Department said Americans have lost $5.5 billion to scam operations run from Southeast Asia since 2022.Reported byAlena KorolevaOCCRPApril 22, 2025A former top anti-corruption official once tasked with sniffing out…

UK insurance broker charged with failure to prevent bribery

Representatives of United Insurance Brokers Limited (UIBL) were ordered to appear before Westminster Magistrates’ Court next month. The broker is charged with failing to prevent associates from bribing state officials in Ecuador between October 2013 and March 2016. The SFO alleges UIBL’s US-based intermediaries for Ecuador paid bribes in return for the awarding of re-insurance contracts worth US$38 million. If this case proceeds to a contested trial, it will be the first time that an SFO “failure to prevent bribery” case is heard by a jury. UIBL offered re-insurance services which insure against any losses caused by making significant and…

UK, France, & Switzerland Join Forces in New Anti-Corruption Taskforce Amid U.S. FCPA Pause

Key Takeaways New Anti-Corruption Taskforce: The UK’s Serious Fraud Office, France’s Parquet National Financier, and Switzerland’s Office of the Attorney General have formed a taskforce to strengthen collaboration and tackle international bribery and corruption. Timely Announcement: The taskforce was announced amid the U.S. decision to pause FCPA enforcement for 180 days, creating potential shifts in global anti-corruption efforts and enforcement priorities.Cross-Border Cooperation: The three agencies will work together more closely, leveraging their expertise and jurisdiction to target cross-border corruption and financial crime.Commitment to Combating Crime: Officials from the UK, France, and Switzerland emphasized the importance of international partnerships in tackling…

‘Several people’ arrested in EU bribery investigation linked to Huawei

Several people have been arrested and homes searched as part of an investigation into alleged bribery and corruption at the European parliament relating to the Chinese technology giant Huawei, Belgian prosecutors have said. The investigating judge in charge of the case has asked for seals to be fixed to the offices of two European parliament assistants alleged to be involved. “The alleged bribery is said to have benefited Huawei,” Belgium’s federal prosecutor said in a statement on Thursday afternoon, after an earlier statement that did not mention the company. The first statement said that several individuals had been arrested for…

FCA bans former Credit Suisse executives following US criminal convictions

The FCA has banned Andrew Pearse and Surjan Singh from the UK financial services industry. The former Credit Suisse managing directors have been banned for lacking integrity, following US convictions for arranging corrupt loans to the Republic of Mozambique. In July 2019, Mr Pearse pleaded guilty in the US for his role in the conspiracy to commit money laundering and wire fraud, which included him accepting over US$45m in unlawful kickbacks in connection with the loans. In September 2019, Mr Singh also pleaded guilty in the US for his role in the conspiracy to commit money laundering, which included him…

McKinsey Africa to Pay $122 Million Over Bribery Scheme Involving South African Officials

McKinsey & Company Africa (Pty) Ltd (McKinsey Africa) will pay $122 million to resolve charges of bribing South African government officials in a years-long scheme. The U.S. Department of Justice (DOJ) announced the settlement as part of a coordinated effort with South African authorities, underscoring the growing international push against corporate corruption. Between 2012 and 2016, McKinsey Africa partnered with South African consulting firms to pay bribes to officials at Transnet and Eskom, the state-owned entities responsible for managing South Africa’s infrastructure and energy. These bribes granted McKinsey Africa access to confidential information, helping the firm secure lucrative consulting contracts.…

AAR CORP. & Former Executive Face $55 Million Penalty Over International Bribery Schemes

AAR CORP., a global aerospace and defense aftermarket solutions company, has agreed to pay over $55 million to resolve U.S. charges related to bribery schemes involving officials in Nepal and South Africa. Between 2015 and 2020, AAR admitted to conspiring to pay bribes to government officials to secure business with state-owned airlines in Nepal and South Africa. In Nepal, the company secured a contract for the sale of two Airbus A330-200 aircraft to Nepal Airlines Corporation by offering and paying bribes through intermediary companies. In South Africa, AAR obtained an aircraft component support contract with South African Airways Technical, a…

China jails ex-football head coach for bribery

The former coach of the Chinese national men’s football team has been sentenced to 20 years in jail for bribery, state media reported.Li Tie, who also played for Everton in the English Premier League, confessed earlier this year to fixing matches, accepting bribes, and offering bribes to get the top coaching job.The case shows how President Xi Jinping’s anti-corruption crackdown has cut through sport, banking and the military.Earlier this week, three former officials from the Chinese Football Association (CFA) were also handed jail sentences for bribery. More than a dozen coaches and players have been investigated.Li, who was the national…

Telefónica Venezolana to Shell Out $85 Million to Settle U.S. Bribery Probe Amid Venezuelan Currency Scandal

Venezuela’s Telefónica Venezolana—a subsidiary of Spanish telecom giant Telefónica S.A.—has agreed to pay over $85 million to resolve allegations of bribery. The telecom firm admitted to a scheme involving payments to Venezuelan officials to gain preferential access to U.S. dollars through a government currency auction, a critical exchange in a nation with tight foreign currency controls. This DOJ settlement spotlights not only the costs of corporate corruption but also the lengths companies sometimes go to work around challenging market conditions in places like Venezuela. In a deferred prosecution agreement (DPA) filed in New York federal court, Telefónica Venezolana conceded to…

Commission presents a new study on areas most at risk of corruption

No area is free from corruption, but certain areas may present higher risks than others. These are areas that involve management of significant public funds or access to critical services, such as health care. On 4 November 2024, the Commission published its study, High-risk areas of corruption in EU Member States: a mapping and in-depth analysis, which was contracted in 2023 to identify areas most at risk of corruption and provide an in-depth analysis of the nature of and reasons behind these risks. Six EU-wide sectors emerged as high-risk areas of corruption where the Commission will be prioritising actions: healthcare,…

Raytheon to Pay Over $950 Million in DOJ Settlement for Defective Pricing, Foreign Bribery, & Export Control Violations

Raytheon Company, a defense giant and subsidiary of RTX, has agreed to pay over $950 million to settle criminal and civil investigations by the Department of Justice (DOJ). The hefty settlement addresses the company’s involvement in fraudulent pricing schemes, violations of the Foreign Corrupt Practices Act (FCPA), and breaches of export control regulations under the Arms Export Control Act (AECA). The DOJ has outlined two significant schemes. The first relates to Raytheon’s fraudulent pricing practices on U.S. Department of Defense (DOD) contracts, while the second involves foreign bribery in Qatar and the company’s failure to properly disclose such conduct in…

U.S. is seizing Los Angeles mansion from family of Armenian politician accused of bribery

The U.S. is seizing a more than 30,000-square-foot Los Angeles mansion from the family of an Armenian politician, a sprawling estate on the Westside which federal prosecutors allege was paid for with millions of dollars in bribes. The home belonging to the family of Gagik Khachatryan is situated in LA’s Holmby Hills neighborhood, wedged between Beverly Hills and Bel Air, and was estimated by U.S. prosecutors to be worth $63.5 million in May 2022. An updated estimated value of the home was not given Monday. But the American government will sell it off for the “highest obtainable market price” and…

Spanish Court Asked to Fine Duro Felguera €160M in Venezuela Alleged Bribery Case

Spanish anti-corruption prosecutors have asked a court to impose a fine of 160 million euros ($173 million) on the engineering and construction company Duro Felguera S.A., which they allege bribed Venezuelan officials in return for securing a contract to build a power plant.Prosecutors have also requested prison sentences and fines for two of Duro Felguera’s previous presidents, as well as Nervis Villalobos, Venezuela’s former energy vice-minister, according to an indictment seen by OCCRP.“All the commissions paid by ‘Duro Felguera’ were aimed at ensuring the company was privileged both in the awarding of the construction of the thermoelectric power plant and…

Moldova Arrests Officials For Helping Criminals Bypass Interpol Red Notices

Moldova detained Tuesday four allegedly corrupt officials tied to an international conspiracy that has allowed criminals to escape Red Notice arrest warrants issued by Interpol. The officials are believed to have accepted bribes totalling several million U.S. dollars in exchange for offering criminals safe harbor in Moldova from Red Notices issued in their names, or for deleting the arrest warrants altogether. Moldova’s Anti-corruption Prosecution Office ordered raids on 33 locations to seek out and detain the suspects, as part of a multilateral investigation that includes federal authorities across the U.K., the U.S., France, and Spain. The conspiracy was revealed by the U.S.…

Fiji’s former Prime Minister Frank Bainimarama jailed for a year

Frank Bainimarama, who was Fiji’s prime minister for some 15 years until losing power in 2022, has been jailed for a year after he was found guilty of using his position to shut down a corruption investigation into a prominent university. Once armed forces chief, Bainimarama seized power in a 2006 coup and later won democratic elections in 2014 and 2018. The 70-year-old narrowly lost the December 2022 election to a coalition of parties led by the current prime minister, Sitiveni Rabuka, but remains a popular figure. Outside the court in Suva on Thursday, a crowd of supporters gathered ahead…

Bribery Rocks Russian Defense Ministry, Senior Officials Detained

Russian authorities detained a senior Defense Ministry official, alleging his involvement in a large-scale bribery scheme exceeding 100 million Russian rubles (just over US$1 million), the Russian Investigative Committee stated Tuesday on its Telegram channel.The Main Investigation Department of the Committee (Следственный комитет Российской Федерации – SLEDKOM) said it has opened “a criminal case against the head of the personnel department of the Defense Ministry, Yury Kuznetsov.”“The investigation reveals that between 2021 and 2023, while serving as the head of the 8th Directorate of the General Staff of the Russian Armed Forces, Kuznetsov allegedly accepted bribes from representatives of commercial…

ACCA report reveals the hidden cost of bribery for SMEs

A new report from the Association of Chartered Accountants (ACCA) has revealed the pervasive impact of bribery and corruption on small and medium-sized enterprises (SMEs) worldwide. The report’s research, titled Bribery and corruption: The hidden social evil on your doorstep, underscores the urgent need for increased transparency and robust regulatory frameworks to combat these issues. It shows a high prevalence and deep concern about the damaging impact of bribery and corruption on SMEs, with more than half (59%) of SMEs and their advisers believing that standing up to bribery and corruption will cost them business trade or opportunities. The UK…

UK Government to tackle global financial corruption 

UK Government to work with international community to tackle illicit flows of money through increased transparency of company ownership.  UK Deputy Foreign Secretary and Minister for Development and Africa Andrew Mitchell will announce a call to action on this issue during the World Bank Spring Meetings.  He will also announce a £2 million funding contribution to tackle corruption in support of the call to action.   Today (Tuesday 16 April), the UK Government will announce a global call to action for greater transparency on company ownership to tackle global illicit flows of money. Transparency about who owns, controls, or benefits from companies is…

Bribery, fraud and anti-money laundering | UK Regulatory Outlook April 2024

Financial Conduct Authority 2024/2025 Business Plan The Financial Conduct Authority (FCA) has published its 2024/25 Business Plan, as a useful reminder of its objectives and areas of regulatory focus for the financial sector. Over the next year, the FCA will focus on reducing and preventing financial crime, prioritising the needs of consumers and strengthening the UK’s position in global wholesale markets. This follows its work update published in February 2024 (as reported in our previous Regulatory Outlook), which highlighted the need for firms to tackle fraud and ensure their systems keep up with the increasing sophistication of criminal groups.   For further information see our Insight.…

China former football chief sentenced to life for bribery

A former president of the Chinese Football Association (CFA), Chen Xuyuan, has been sentenced to life in prison for bribery, according to the country’s state media. In January, he pleaded guilty to taking bribes worth a total of 81 million yuan ($11.2m; £8.9m). An anti-corruption crackdown led by President Xi Jinping has cut through sport, banking and the military. In football, more than a dozen coaches and players have been investigated. The trial at the Intermediate People’s Court of Huangshi in central China revealed Chen’s illicit activities from 2010 to 2023, which included his earlier role as the president and…

Gunvor S.A. to Pay Over $661M in Landmark Guilty Plea for Foreign Bribery Case

Gunvor S.A., an international commodities trading company based in Switzerland, has pleaded guilty and agreed to pay over $661 million to settle an investigation by the U.S. Justice Department, resolving allegations of violations of the Foreign Corrupt Practices Act (FCPA). The guilty plea follows an extensive probe into Gunvor’s corrupt practices, specifically its scheme to pay substantial bribes to Ecuadorean government officials with the aim of securing business deals with Petroecuador, the state-owned and state-controlled oil company of Ecuador. As part of the resolution, Gunvor entered into a plea agreement, admitting to conspiracy charges related to violating the anti-bribery provisions…

Two men acquitted of bribing Saudis in huge British defence deal

Two men have been acquitted of paying bribes totalling millions of pounds to high-ranking Saudis after they argued that they had been unfairly prosecuted. Jeffrey Cook and John Mason had been accused of bribing a Saudi prince and his associates to secure and maintain a huge defence deal for a British company. But on Wednesday, a jury in London acquitted them after lawyers argued the payments had been authorised by the British and Saudi governments. Tom Allen, the KC representing Cook, had told jurors at Southwark crown court that a wide array of British politicians, officials and military figures had…

Expensive Art at Stake as Venezuelan Banker Faces U.S. Bribery Charges

He’s already facing charges for allegedly bribing a former Puerto Rican governor, and his bank is in liquidation following money laundering fines. Now, Julio Herrera Velutini has another legal concern: the state of his confiscated US$23-million art collection. Administrators in charge of liquidating his bank’s assets have “stashed” the collection “under conditions that seem inadequate for its proper preservation,” according to a lawsuit recently filed by Herrera Velutini. Herrera Velutini made the claims against Driven Administrative Services LLC, which has been appointed to administer Bancrédito International Bank and Trust Corporation. Herrera Velutini is the sole shareholder of Bancrédito Holding, the…

Bribery, fraud and anti-money laundering | UK Regulatory Outlook February 2024

The Environment Agency has established a new Economic Crime Unit to combat money laundering and conduct financial investigations in the waste sector, made up of accredited financial investigators and financial intelligence officers and financial crime analysts. The unit comprises two teams: the Asset Denial Team, focusing on account freezing orders, cash seizures, pre-charge restraints and confiscations; and the Money Laundering Investigations team, responsible for conducting money laundering investigations targeting environmental offences. Businesses within the waste sector should ensure they are adhering to proper financial practices and reporting any suspicious activities. It is crucial that should the Economic Crime Unit launch…

Tory MP earns £900 an hour from arms firm run by bribery suspect

A Conservative MP is set to earn £900 an hour from a North Macedonian arms company whose owner was embroiled in a bribery scandal, openDemocracy can reveal. Mark Pritchard, who has been the MP for The Wrekin since 2005, began working for the firm ATS Group in November – but only declared it in Parliament’s transparency register last week. ATS Group’s owner and CEO was arrested in Belgrade in 2019 following a months-long investigation by Serbian authorities into allegations of bribery over the alleged theft of technical documents from a rival arms manufacturer in Užice, Serbia. In the latest register…

UN Staff on £1.5bn Iraq Aid Project ‘Demanding Bribes’

Staff working for the UN in Iraq are allegedly demanding bribes in return for helping businessmen win contracts on postwar reconstruction projects in the country, a Guardian investigation has found. The alleged kickbacks are one of a number of claims of corruption and mismanagement the Guardian has uncovered in the Funding Facility for Stabilization, a United Nations Development Programme (UNDP) scheme launched in 2015 and backed by $1.5bn (£1.2bn) in support so far from 30 donors, including the UK. Since the 2003 US-led invasion, the international community has pumped billions of aid dollars into Iraq. Twenty years on, the country…

US Prosecutors Empowered to Charge Foreign Officials with Bribery

In a significant stride toward combating global corruption, the United States has enacted the Foreign Extortion Prevention Act (FEPA), allowing federal prosecutors to bring criminal charges against foreign government officials soliciting or accepting bribes from U.S. companies. The newly minted law, a component of the National Defense Authorization Act, addresses a longstanding gap in the fight against corruption, as it criminalizes the “demand” side of cross-border corruption, providing a crucial addition to the Foreign Corrupt Practices Act (FCPA). Historically, the U.S. government has focused on charging U.S. companies for engaging in corrupt practices overseas under the FCPA. However, the ability…

SEC Charges Global Software Company with Bribery

The U.S. The Securities and Exchange Commission (SEC) has charged SAP, a multinational software company, with violating the Foreign Corrupt Practices Act by bribing government officials at least in seven countries including South Africa, Malawi, Kenya, Tanzania, Ghana, Indonesia, and Azerbaijan. According to the Jan. 10 official press release, between December of 2014 and January of 2022 “SAP employed third-party intermediaries and consultants to bribe government officials to obtain business with public sector customers in the seven countries.” The company, based in Germany, “inaccurately recorded the bribes as legitimate business expenses in its books and records, despite the fact that…