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United Technologies Corp. Resolves $13.9 Million Enforcement Action

By on September 13, 2018 in 2018 Enforcement Actions, Aviation Industry, Azerbaijan, Building Systems, China, Distributor Issues, Gifts, Indonesia, Internal Controls, International Aero Engines, Joint Venture, Kuwait, Otis Elevator, Pakistan, Pratt & Whitney, Russia, SEC Enforcement Action, South Korea, Thailand, Third Parties, Travel and Entertainment, United Technologies
UTC

Yesterday, the SEC announced that United Technologies Corporation resolved a $13.9 million Foreign Corrupt Practices Act enforcement action.

The conduct at issue concerned Otis Elevator Co. (a wholly-owned subsidiary of UTC), Pratt & Whitney (an operating division of UTC), and International Aero Engines (a joint venture of five aerospace companies including Pratt & Whitney) regarding a Russian and Azerbaijani improper payment scheme, a China aviation scheme, improper payments for Otis Elevator sales in China, and leisure travel for foreign officials from several countries including China, Kuwait, South Korea, Pakistan, Thailand, and Indonesia.

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

By on December 28, 2016 in 2016 Enforcement Actions, Aviation Industry, Daniel Perez, DOJ Enforcement Action, Douglas Ray, Ernesto Hernandez Montemayor, FCPA Related Charges, Hunt Pan Am Aviation, Individual Enforcement Action, Kamta Ramnarine, Mexico, Ramiro Ascencio Nevarez, Undercover Investigations, Victor Valdez
FBO

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

By on November 1, 2016 in Airline Industry, Aviation Industry
Radar Screen

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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