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DOJ Quietly Releases “Declination With Disgorgement” Letter Involving JLT


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”


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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