The Insurance Corporation of Barbados Limited (ICBL) received a declination with disgorgement from the DOJ Thursday for FCPA offenses related to bribing a Barbadian official.
Under the terms of the declination pursuant to the DOJ’s Corporate Enforcement Policy, ICBL paid the DOJ about $93,900 in disgorged profits.
The DOJ said agents and employees of the Barbados-headquartered company paid around $36,000 to a Barbadian government official, Donville Inniss, in exchange for $686,000 worth of insurance contracts.
Inness was a member of the parliament of Barbados and the Minister of Industry, International Business, Commence, and Small Business Development at the time.
The DOJ said Inness laundered the money in the United States through a New York-based dental company owned by his friend.
The DOJ gave ICBL credit for its timely and voluntary self-disclosure, thorough investigation, and remediation through firing of the individuals involved, among other factors.
ICBL is the first declination with disgorgement under the FCPA Corporate Enforcement Policy (pdf) that went into effect in November 2017.
The new policy made the FCPA Pilot Program permanent and incorporated it, with some changes, into the U.S. Attorneys’ Manual.
Harry Cassin is the managing editor of the FCPA Blog.