As highlighted in this prior post, in August 2018 the DOJ quietly released a so-called declination with disgorgement letter concerning Insurance Corporation of Barbados Ltd. (ICBL).
Pursuant to the agreement, ICBL agreed to pay approximately $94,000 for alleged bribes to a Barbadian government official in exchange for insurance contracts. As noted in the prior post, Donville Inniss (the “foreign official”) was charged with money laundering offenses.
In an August 2018 superseding indictment recently unsealed by the DOJ, Ingrid Innes (a Canadian citizen, resident of Barbados and former CEO of ICBL) and Alex Tasker (a citizen and resident of Barbados and former senior VP of ICBL) were also charged – not with FCPA anti-bribery violations – but with money laundering offenses. (For media coverage see here, for the DOJ’s release see here).
As alleged in the indictment:
Between August 2015 and April 2016, Inniss “leveraged his position as the Minister of Industry and engaged in a scheme to accept approximately $36,000 in bribes from ICBL … and to launder that money to and through the U.S. ICBL employees, including Innes and Tasker, agreed to pay bribes to Inniss, who, in return, agreed to use his official position as the Minister of Industry to cause [the Barbados Investment and Development Corp.] to renew insurance contracts with ICBL.”
According to the indictment, Inness and Tasker and another ICBL executive caused the bribe payments to Inniss to be paid through the U.S. bank account in the name of a New York Dental Company [with an address in Elmont, NY], which had no actual business with ICBL.”