AAR Resolves $55.6 Million FCPA Enforcement Action

As highlighted in this prior post, in July, Julian Aires (an individual associated with a joint venture partner of AAR Corp. – a U.S. based aviation services company) pleaded guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with business dealings with South Africa Airways (SAA) as well as a contract involving Swissport and SAA.
As highlighted in this prior post, in August, Deepak Sharma (an agent of AAR and the former President of Integrated Solutions at AAR) pleaded guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with a bribery scheme involving Nepal Airlines Corporation.
Yesterday, it was AAR’s turn as the DOJ and SEC announced (here and here) an FCPA enforcement action against the company based on the same core conduct.
The enforcement action involved a DOJ component (net $26.4 million) and an SEC component ($29.2 million).
Scrutiny Updates

AAR Corp.
As highlighted in this prior post, in July, Julian Aires (an individual associated with a joint venture partner of AAR Corp. – a U.S. based aviation services company) pleaded guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with business dealings with South Africa Airways (SAA) as well as a contract involving Swissport and SAA.
As highlighted in this prior post, in August, Deepak Sharma (an agent of AAR and the former President of Integrated Solutions at AAR) pleaded guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with a bribery scheme involving Nepal Airlines Corporation.
Yesterday, AAR disclosed in its quarterly filing:
Individual Pleads Guilty To FCPA Charge In Connection With Bribery Scheme Involving South African Airways

In 2016, AAR Corp. (a U.S. based aviation services company) announced that it had teamed with a joint venture partner – JM Aviation South Africa (Pty) Ltd. – to secure a five year contract to provide inventory management and repair services to South Africa Airways Technical (SAAT) Ltd. (a wholly-owned subsidiary of South African Airways – SAA).
Recently, the DOJ charged Julian Aires (a U.S. citizen who resided in San Diego and associated with JM Aviation South Africa) with conspiracy to violate the FCPA’s anti-bribery provisions in connection with an SAAT contract as well as another contract involving Swissport (an airport ground services and air cargo handling company) and SAA.
According to the court docket, Aires has pleaded guilty.
Friday Roundup

Scrutiny alert, the irony of it all, just saying …, not sure why, no more third parties, and for the reading stack. It’s all here in the Friday roundup.
Scrutiny Alerts
AAR Corp.
The company, a provider of aviation services with numerous U.S. government contracts, recently disclosed:
“The Company retained outside counsel to investigate possible violations of the Company’s Code of Conduct, the U.S. Foreign Corrupt Practices Act, and other applicable laws, relating to the Company’s activities in Nepal and South Africa. Based on these investigations, we self-reported these matters to the U.S. Department of Justice, the U.S. Securities and Exchange Commission and the UK Serious Fraud Office. The Company will fully cooperate in any review by these agencies, although we are unable at this time to predict what action, if any, they may take.”