By
Adrianne Appel2022-11-07T20:56:00
Insurance broker Arthur J. Gallagher is under investigation by the Department of Justice (DOJ) related to its business in Ecuador, the company told the Securities and Exchange Commission on Nov. 2.
The Foreign Corrupt Practices Act (FCPA) unit of the DOJ delivered a subpoena to Gallagher during the second quarter of 2022, “seeking information related to our insurance business with public entities in Ecuador,” the company said in its financial Form 10-Q for the period that ended Sept. 30.
The company declined to comment about the subpoena, a spokesperson said in an email. Gallagher, which brings in more than $6 billion in annual revenue, has 850 offices worldwide, including one in Guayaquil, Ecuador.
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It has been nearly six months now since the Department of Justice’s (DOJ) Criminal Division released its memorandum on the selection of compliance monitors. This article provides a critical analysis of the monitorships that received early terminations, those that remain in place, and the broader compliance lessons they impart.
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