For those who might have wondered if the Jeff Sessions’ Justice Department was going to enforce the Foreign Corrupt Practices Act (FCPA), that question seems to have been answered in the affirmative. In September, the DoJ and Securities and Exchange Commission announced the largest FCPA fine ever, that being against Telia Company at $965MM. Now we have five criminal matters involving individuals who all were involved in the Rolls Royce corruption case, in which the corporate matter had been resolved in January before the new administration took power.

This week, the Justice Department announced it had secured guilty pleas from four individuals, James Finley, Aloysius Zuurhout, Andreas Kohler, and Keith Barnett. There was one Indictment brought against against Petros Contoguris. All of the individuals were involved in a wide-ranging corruption scheme used by Rolls Royce to pay bribes to receive international contracts, primarily around a gas pipeline in Central Asia which it built for a joint venture owned by Kazakhstan and Chinese state-owned enterprises. The bribery scheme netted Rolls Royce contracts worth approximately $145 million in revenues.

The bribery scheme involved fraudulent Commission payments kickbacks to Contoguris company, Gravitas, which would then pay the monies out as bribes to foreign officials. The scheme was in place for almost 10 years. The U.K. Serious Fraud Office stated in a press release that “The SFO’s investigation in respect of the conduct of individuals in Rolls-Royce Civil, Defence, Marine, and former Energy Divisions continues. The SFO and DoJ continue to cooperate in their parallel investigations.” This may portend additional individual prosecutions in either the United Kingdom or United States.