FCPA Lessons From The Allianz Settlement

Law360, New York ( January 14, 2013, 12:27 PM EST) -- On Dec. 17, 2012, the U.S. Securities and Exchange Commission announced a settlement under the U.S. Foreign Corrupt Practices Act with Allianz SE, the insurance company based in Germany, resulting in $5.3 million in civil penalties and more than $7 million in disgorgement and interest. The settlement stemmed from a two-year investigation into allegations that an Allianz subsidiary paid bribes to government officials in Indonesia over a seven-year period and violated the FCPA's books and records and internal controls provisions. The U.S. Department of Justice started its own investigation into potential criminal liability for Allianz, but closed its case in 2011 with a declination letter, an event that was reported in the Wall Street Journal....

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