FCPA: The BizJet DPA: Cooperation is the Key

Last week, the Department of Justice (DOJ) announced the resolution of an enforcement action under the Foreign Corrupt Practices Act (FCPA) involving the Tulsa based company, BizJet. The company is in the business of providing aircraft maintenance, repair and overhaul services (MRO) to customers in the US and internationally. BizJet ran into FCPA trouble regarding its Latin American operations, specifically in the countries of Mexico and Panama. BizJet employees and executives were involved in multi-year running bribery scheme which paid hundreds of thousands of dollars for these MRO contracts. These payments were discussed at the highest levels of the company, including the Board of Directors, and occurred from 2004 until 2010.

BizJet Bribery Box Score

The Deferred Prosecution Agreement (DPA) listed the following instances of recorded bribery, a/k/a the “BizJet Bribery Box Score”.

BizJet Executive or Employee Named Payment Made To Amount of Payment Others Involved Sales Manager A Official 6 Cell Phone and $10K Executive B and C Sales Manager A Official 3 $2K Executive B Executive B, C and Sales Manager A Official 2 $20K Executive C Official 2 $30K Sales Manager A Executive B Mexican Federal Police Chief $10K Executive C and Sales Manager. A Executive C Official 5 $18K Sales Manager A Sales Manager A Official 4 $50K Sales Manager A Mexican Federal Police $176 Executive C Sales Manager A Official 4 $40K Sales Manager A Mexican Federal Police $210K Executive C Sales Manager A Official 5 $6K Executive C Executive C Official 5 $22K

The above bribes were characterized as “commission payments” and “referral fees” on the company’s books and records. Payments were made from both international and company bank accounts here in the United States ...

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