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Yet Additional FCPA Enforcement Actions Concerning Ecuador’s Seguros Sucre

seguros

From time to time, there are certain Foreign Corrupt Practices Act enforcement actions in which the core allegations just seem to “keep on giving” and spawn several related enforcement actions.

A prime example were the many FCPA (and related) enforcement actions involving Haiti Teleco from approximately ten years ago (see here) and the many recent enforcement actions concerning Venezuela’s PDVSA.

Enforcement actions concerning Ecuador’s Seguros Sucre S.A. (“Seguros Sucre”), an alleged state-owned insurance company and “instrumentality” of the Ecuadorian government, are beginning to add up as well. In 2022 U.K.-based reinsurance broker, Jardine Lloyd Thompson Group Holdings Ltd. (JLT) resolved a $29 million FCPA enforcement action (see here for the prior post) and eight individuals have been criminally charged (and several have pleaded guilty) in connection with the same underlying conduct.

The latest enforcement action was yesterday’s announcement by the DOJ that Tysers Insurance Brokers Limited (Tysers – formerly known and doing business during the relevant time period as Integro Insurance Brokers Limited an international reinsurance broker based in the United Kingdom) and H.W. Wood Limited (an international reinsurance broker based in the United Kingdom) resolved a Foreign Corrupt Practices Act enforcement action for “participation in a corrupt scheme to pay bribes to Ecuadorian government officials.”

The net settlement amount in the Tysers enforcement action is $46.5 million and the net settlement amount in the H.W. Wood enforcement action is $508,000 based on inability to pay.

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Another Enforcement Action Involving Ecuador’s Seguros Sucre

seguros

From time to time, there are certain Foreign Corrupt Practices Act enforcement actions in which the core allegations just seem to “keep on giving” and spawn several related enforcement actions.

A prime example were the many FCPA (and related) enforcement actions involving Haiti Teleco from approximately ten years ago (see here) and the many recent enforcement actions concerning Venezuela’s PDVSA.

Enforcement actions concerning Ecuador’s Seguros Sucre S.A. (“Seguros Sucre”), an alleged state-owned insurance company and “instrumentality” of the Ecuadorian government are beginning to add up.

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DOJ Quietly Releases “Declination With Disgorgement” Letter Involving JLT

DOJ2

This March 15th post discussed a future $29 million “declination with disgorgement” enforcement action disclosed by Marsh & McLennan Companies, Inc. in connection with its 2019 acquisition of Jardine Lloyd Thompson Group plc (JLT).

On March 22nd, the DOJ quietly updated its FCPA Corporate Enforcement Policy declinations page by posting the March 18th “declination with disgorgement” letter.

The last time the DOJ self-identified an FCPA enforcement action as a “declination” was approximately 1.5 years ago (in August 2020).

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Marsh Discloses Future $29 Million “Declination With Disgorgement”

Marsh

In April 2019, Marsh & McLennan Companies, Inc. completed the acquisition of Jardine Lloyd Thompson Group plc (JLT).

Prior to the acquisition, JLT identified payments to a third-party introducer that had been directed to unapproved bank accounts. These payments related to reinsurance placements made on behalf of an Ecuadorian state-owned insurer between 2014 and 2017. In early 2018, JLT voluntarily reported this matter to law enforcement authorities.

In February and March 2020, money laundering charges were filed in the United States against a former employee of JLT, the principals of the third-party introducer and a former official of the state-owned insurer. These individuals, including the former JLT employee, have since pleaded guilty to criminal charges. (See here, see also this prior post).

Recently, Marsh disclosed:

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DOJ Quietly Releases “Declination With Disgorgement” Letter Agreement Concerning Insurance Corp. Of Barbados Ltd.

icbl

Yesterday, the DOJ quitely posted to its FCPA website this “declination with disgorgement” letter concerning Insurance Corporation of Barbados Limited (ICBL).

Pursuant to the agreement, ICBL agreed to pay approximately $94,000 to the U.S. for alleged bribes to a Barbadian government official in exchange for insurance contracts.

The full text of the DOJ’s letter to ICBL’s counsel (Adam Siegel – Freshfields Bruckhaus Deringer) is as follows.

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