BizJet’s High Flying Cooperation Dividend

When BizJet paid $11.8 million this week to settle an FCPA conspiracy count, it received a huge discount from the DOJ.

According to the Federal Sentencing Guidelines, BizJet’s base fine calculation was $28.5 million.

After applying so-called ‘multipliers,’ the fine range was $17.1 million to $34.2 million.

So BizJet’s reduction was 30% off the bottom of the fine range, and a whopping 65% off the top of the fine range.

How’d that happen?

The deferred prosecution agreement said:

‘BizJet and the [DOJ] agree that this fine is appropriate given the facts and circumstances of this case, including the nature and extent of BizJet’s voluntary disclosure, extraordinary cooperation, and extensive remediation in this matter. The $11,800,000 is final . . . . ‘

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BizJet’s March 14, 2012 deferred prosecution agreement with the DOJ can be downloaded here (pdf).