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).
Individual Pleads Guilty To A Bribery Scheme Involving Nepal Airlines

Last month, 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. (See here for the prior post).
It was noted that the enforcement action was likely the first of several related enforcement actions to come as AAR’s recent annual report disclosed FCPA scrutiny in South Africa as well as Nepal.
Sure enough.
Recently, Deepak Sharma (pictured) (a United Kingdom citizen and resident) pleaded guilty to conspiracy to violate the FCPA’s anti-bribery provisions in connection with a bribery scheme involving Nepal Airlines Corporation (“NAC”), an alleged instrumentality of the Nepali government.