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DOJ Announces Criminal Charges And Plea Agreements In Connection With Mexican Aviation Bribery Scheme

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This recent post highlighted the many Foreign Corrupt Practices Act enforcement actions involving the aviation industry.

Add another to this long list as yesterday, the DOJ announced that criminal charges “were unsealed against six individuals, all of whom have pleaded guilty for their involvement in schemes to bribe Mexican officials in order to secure aircraft maintenance and repair contracts with government-owned and controlled entities, and two for conspiring to launder the proceeds of the schemes.”

The criminal FCPA conspiracy charges were against four individuals: Daniel Perez, Kamta Ramnarine, Victor Valdez, and Douglas Ray.

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Not Flying Under The Radar – The Many FCPA Enforcement Actions Against Companies In The Aviation Industry

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When compiling a list of the industries that have the highest Foreign Corrupt Practices Act risk, the aviation industry is probably not going to be near the top of many lists.

However, it should be because as highlighted in this post there have been approximately 15 corporate FCPA enforcement actions against companies in the industry (broadly defined) throughout FCPA enforcement history. Last week’s enforcement action against Embraer (see here and here for prior posts) was merely the most recent example, albeit most high-profile given the settlement amount.

Indeed, the aviation industry was front and center in “The Story of the Foreign Corrupt Practices Act” as Lockheed’s payments to Japanese Prime Minister Tanaka, Prince Berhard (the Inspector General of the Dutch Armed Forces and the husband of Queen Juliana of the Netherlands) and Italian political parties was arguably the most high profile example of the foreign corporate payments problem Congress learned about in the mid-1970’s which motivated it to enact the FCPA.

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