In December 2024, McKinsey and Company Africa (Pty) Ltd., a wholly owned and wholly controlled subsidiary of McKinsey & Company (an international consulting firm) resolved a net $61.4 million Foreign Corrupt Practices Act enforcement action based on alleged bribery schemes in South Africa.
The conduct at issue largely focused on Vikas Sagar (a citizen of India, a lawful permanent resident of the United States, and resident of South Africa) who was a partner and senior partner of McKinsey working in McKinsey’s office in Johannesburg, South Africa, and a stockholder, employee, and agent of McKinsey.
In connection with the same conduct alleged in the corporate enforcement action, the DOJ also announced the unsealing of a guilty plea in which Sagar pleaded guilty to conspiracy to violate the FCPA’s anti-bribery provisions. (The criminal charges against Sagar were filed in December 2022).
Earlier this week, Sagar was sentenced to time served, ordered to pay a $250,000 fine, and required to “return home to India within 72 hours of sentencing.”
The docket entry states:
“Minute Entry for proceedings held before Judge Colleen McMahon: Sentencing held on 9/24/2025 for Vikas Sagar (1) Count 1. Defendant present with his attorneys Brian Blais, Katherine Kleinot, and Ryan Rohlfsen; AUSAs Andrew Chan, William Schurmann, and Nicholas Chiuchiolo. (Transcript of proceeding is sealed.) Defendant is sentenced to a term of imprisonment of TIME SERVED; to pay a fine of $250,000.00, within 30 days of sentencing; and to a supervised release term of THREE (3) YEARS. The Court recommends that the defendant be supervised on a long-distance basis from his home in India, by the Southern District of New York. Defendant should be required to check in with his probation officer, at least twice a month. In addition to the mandatory and standard conditions, except for the mandatory drug-testing condition, which is waived, the following special conditions apply: You must obey the immigration laws and comply with the directives of immigration authorities. Defendant is to return home to India within 72 hours of sentencing. You must provide the probation officer with access to any requested financial information. You must not incur new credit charges or open additional lines of credit without the approval of the probation officer, unless you are in compliance with the payment schedule, for the criminal monetary penalties. (Court Reporter Douglas Colavito) (ap) (Entered: 09/24/2025)”
