As I summarized in this video, the DOJ and SEC reached settlements last week with Panalpina World Transport (Holding) Ltd. and six other companies in the oil services industry related to alleged bribery of foreign officials. The government alleged that the companies paid a total of $156 million dollars in bribes to foreign officials to receive preferential treatment and improper benefits during the customs process.
Yesterday, law firm Troutman Sanders issued an Alert on its website that linked to the many documents in the criminal cases, including the DOJ’s criminal informations and the deferred prosecution agreements for many defendants. Troutman Sanders noted that each of the deferred prosecution agreements posted by the DOJ incorporated an attachment entitled, “Corporate Compliance Program.” By its terms, the “Corporate Compliance Program” requires each company “to address deficiencies in its internal controls, policies, and procedures regarding compliance with the Foreign Corrupt Practices Act,” in a manner that will at a minimum include certain elements also laid out in the CCP.
