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Scrutiny Alert 

As highlighted in this prior post, there have been several FCPA (and related) enforcement actions involving Ecuador’s Seguros Sucre S.A., an alleged state-owned insurance company and “instrumentality” of the Ecuadorian government.

Recently, Arthur J. Gallagher & Co. (an Illinois based insurance brokerage, risk management and consulting services firm and a “World’s Most Ethical Company” for 11 consecutive yearsdisclosed:

“During third quarter 2022, we received a subpoena from the FCPA Unit of the U.S. Department of Justice seeking information related to our insurance business with public entities in Ecuador. We are fully cooperating with the investigation. Based on the current status, we do not believe a material loss, if any, is probable.”


As highlighted in this prior post, in August 2019 the DOJ announced that Robin Longoria (an individual associated with European Adoption Consultants – an Ohio-based adoption agency) pleaded guilty to one count of conspiring to violate the FCPA’s anti-bribery provisions and to commit wire fraud and visa fraud “for her role in a scheme to corruptly facilitate adoptions of Ugandan children through bribing Ugandan officials and defrauding U.S. adoptive parents and the U.S. Department of State.”

As highlighted here, in August 2020 the DOJ returned to the core action and announced additional individual FCPA criminal charges, among others. Debra Parris (an individual responsible for managing aspects of the Adoption Agency’s Uganda program) and Dorah Mirembe (a Ugandan citizen and resident who provided adoption-related services to the Adoption Agency including legal representation) were charged with one count of conspiracy to violate the FCPA, three substantive FCPA charges, as well other criminal charges. Separately, Parris and Margaret Cole (Executive Director of the Adoption Agency) were also charged with various criminal charges in connection with Polish adoption issues (that did not implicate the FCPA).

In 2021, the DOJ announced that Parris pleaded guilty “to schemes to procure adoptions of Ugandan and Polish children by bribing Ugandan officials and defrauding U.S. authorities.”

As highlighted in this article, Parris was recently sentenced to one year in prison and ordered to pay a $10,000 fine and $118,000 in restitution. The article notes:

The judge [U.S. District Judge James Gwin] said he would have given her a longer sentence if not for her severe health issues, which includes a failing liver.

“The amount of damage you’ve done to these children is horrendous,” Judge Gwin said of the Ugandan situation. “To be taken away from their own families and put in orphanages and then put into adoptions. It’s difficult to measure the amount of psychological damage that would have occurred to these children, as well as the psychological damage associated with their parents.”


“So for almost three years, I dealt with someone that was dying,” she said. “And I should have read my emails much better. That is my fault. But I still tried to take care of my couples.”

As mentioned in the article, Cole was previously sentenced to three months in prison, Longoria was sentenced to one year, and Mirembe remains at large.


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