One company’s voluntary self-disclosure, two companies’ FCPA settlements

The Department of Justice (DOJ) has made no secret about its incentives for companies to come forward with information on apparent corporate misconduct for the chance to earn discounted or reduced penalties—even a declination.

An example of a successful voluntary self-disclosure is U.K.-based insurance broker Jardine Lloyd Thompson Group Holdings (JLT). The firm was notified in March 2022 it would not face prosecution for alleged bribes paid to Ecuadorian government officials by an employee and other company agents after self-reporting to the DOJ, cooperating with the agency’s subsequent investigation, timely remediation, and agreeing to disgorge more than $29 million in ill-gotten gains.

Case closed for JLT. Cases opened for Tysers Insurance Brokers and H.W. Wood.