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UK insurance company receives declination with disgorgement from DOJ

Jardine Lloyd Thompson Group Holdings Ltd., owned by Marsh & McLennan Companies, Inc., was notified by the DOJ that it would decline prosecution and credit $29 million in disgorgement the company paid to the UK Serious Fraud Office.

The DOJ said pursuant to its Corporate Enforcement Policy, Justice Manual (JM) 9-47.120, and the Principles of Federal Prosecution of Business Organizations, JM 9-28.300, that it would decline to prosecute the UK-based insurance company for violations of the Foreign Corrupt Practices Act.

The DOJ’s declination letter dated March 18, 2022 said the agency would credit 100 percent of the $29 million in disgorgement the company paid to the SFO.

The DOJ found bribery in Ecuador totaling around $3.1 million but declined to bring an FCPA enforcement action, citing the company’s self-disclosure, proactive cooperation, and remediation.

Beginning in 2014 and continuing through 2016, an employee and agents of Jardine Lloyd Thompson paid about $10.8 million to a Florida-based intermediary, knowing that about $3.1 million would be paid in bribes to Ecuadorian government officials, the DOJ said.

The bribes helped Jardine Lloyd Thompson obtain and retain contracts with the Ecuadorian state surety company, Seguros Sucre.

According to the DOJ, around $1.2 million of the bribes were laundered through bank accounts in the United States.

This is the first declination letter the DOJ has published since World Acceptance Corporation’s declination with disgorgement in August 2020. The company paid the SEC $21.7 million in that FCPA resolution, and the DOJ declined to prosecute.

The DOJ issued its first declination with disgorgement in 2016 under the Pilot Program to encourage companies to self-report potential FCPA violations and cooperate in federal investigations.

As part of Jardine Lloyd Thompson’s declination with the DOJ, the company agreed to continue cooperating with ongoing investigations. 

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