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Brazilian Aircraft Maker Resolves FCPA Charges for Over $205 Million

Federal Issues FCPA International SEC Compliance DOJ

Federal Issues

A Brazilian aircraft manufacturer, will pay more than $205 million to the SEC and the DOJ to resolve alleged FCPA violations stemming from payments made through its third-party agents to officials in the Dominican Republic, Saudi Arabia, and Mozambique that allegedly resulted in more than $83 million in profits for the company. Pursuant to a Deferred Prosecution Agreement with DOJ, the Brazilian company must pay a penalty of more than $107 million and must retain an independent corporate compliance monitor for three years. The company will also pay more than $98 million in disgorgement and interest to the SEC, but it may receive a credit of up to a $20 million depending on the amount of disgorgement it pays in a parallel civil proceeding in Brazil. Additional FCPA Scorecard coverage of the company's investigation can be found here, here, and here.

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