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Inquiry Closed


Interactions with Ecuador’s Seguros Sucre, an alleged state owned insurance company, have resulted in three FCPA enforcement actions.

Jardine Lloyd Thompson Group Holdings (March 2022).

Tysers Insurance Brokers (November 2023).

H.W. Wood Limited (November 2023).

During the third quarter of 2022, Illinois based Arthur J. Gallagher & Co. disclosed that it received a subpoena from the FCPA Unit of the DOJ “seeking information related to our insurance business with public entities in Ecuador.”

However, in this recent filing, the company disclosed:

“During the fourth quarter of 2023, the DOJ informed us that it has closed its inquiry and would not be pursuing enforcement action against us.”


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