Last week’s $4.7 million enforcement action against Liberty Mutual regarding an alleged bribery scheme in India was just the latest FCPA enforcement action against an insurance company.
This post highlights the six other enforcement actions.
Tysers and H.W. Wood
In 2023 the DOJ brought related FCPA enforcement actions against United Kingdom reinsurance brokers Tysers and H.W. Wood concerning an alleged bribery scheme in Ecuador.
The net settlement amount in the Tysers matter was $46.5 million and the net settlement amount in the H.W. Wood matter was $508,000.
Jardine Lloyd
In 2022 the DOJ brought a $29 million FCPA enforcement action against U.K. based Jardine Lloyd Thompson Group (acquired by Marsh & McLennan in 2019) in concerning an alleged bribery scheme in Ecuador.
Insurance Corp. of Barbados
In 2018 the DOJ brought an FCPA enforcement action against Insurance Corp. of Barbados concerning an alleged bribery scheme in Barbados. The settlement amount was $94,000.
Aon
In 2011, the DOJ and SEC brought parallel FCPA enforcement actions against Aon concerning alleged bribery schemes in Bangladesh, Bulgaria, Egypt, Indonesia, Myanmar, Panama, the United Arab Emirates, and Vietnam. Total fines and penalties were approximately $16.3 million ($1.8 million via a DOJ non-prosecution agreement and $14.5 million via a settled SEC civil complaint).
Allianz
In 2012 the SEC brought a $12.3 million FCPA enforcement action against Allianz concerning an alleged bribery scheme in Indonesia.
