By Alex Oh and Mark Mendelsohn ( July 5, 2017, 11:28 AM EDT) -- On June 16, 2017, the U.S. Department of Justice issued a declination letter to Linde North America Inc. and Linde Gas North America LLC (collectively, "Linde"), American subsidiaries of a German multinational chemical company, closing an investigation against Linde for potential violations of the Foreign Corrupt Practices Act. As part of the declination, the DOJ required Linde to disgorge and forfeit over $11 million dollars obtained from, or relating to, the alleged corrupt scheme. The Linde declination is the sixth declination issued by the DOJ since it announced the Fraud Section's FCPA enforcement plan and guidance, or the pilot program, on April 5, 2016,[1] and the third declination where the DOJ required a company to disgorge profits received from the alleged improper conduct.[2]...
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