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On December 10, 2014, the DOJ announced that it was settling FCPA charges with Dallas Airmotive, a company that provides aircraft engine maintenance services, after the company admitted to having violated the FCPA and agreed to pay a $14 million fine. A criminal information filed as part of the settlement charged the company with bribing government officials in Brazil, Peru and Argentina from 2008 to 2012 in exchange for contracts to provide maintenance and repair services on state-owned aircraft engines. According to the criminal information, Dallas Airmotive used "front" companies and third parties to pay bribes, and also directly provided things of value, such as paid vacations, to government officials. As part of the settlement, the company entered into a deferred prosecution agreement with DOJ. The company admitted to paying the bribes in a statement of facts accompanying the deferred prosecution agreement. In comments to the Wall Street Journal, Dallas Airmotive announced that the individuals responsible for the improper payments are no longer with the company. The settlement with Dallas Airmotive follows the recent FCPA-related settlement between the DOJ and BizJet, a subsidiary of Lufthansa Technik AG, which also concerned allegedly improper payments to government officials in Latin America in exchange for business related to aircraft maintenance and repair. In 2012, BizJet entered into a deferred prosecution agreement and agreed to pay an $11.8 million fine as part of the settlement, while Lufthansa entered into a non-prosecution agreement.
On July 18, 2012, aircraft maintenance, repair and overhaul ("MRO") provider, Nordam Group, Inc., resolved an FCPA matter with the US DOJ related to conduct in China. The non-prosecution agreement calls for a $2 million penalty, and makes this the second aviation services FCPA matter this year, joining Lufthansa Technik AG's MRO subsidiary, BizJet International Sales and Support, Inc.
- Non-Prosecution Agreement
- NPA Attachment A - Statement of Facts
- NPA Attachment B - Compliance Undertakings
On March 14, 2012, aircraft maintenance, repair and overhaul ("MRO") provider, BizJet International Sales and Support, Inc., resolved an FCPA matter with the US DOJ related to conduct in Latin America, including Mexico and Panama. The deferred-prosecution agreement calls for an $11.8 million penalty. BizJet is an indirect subsidiary of the German company, Lufthansa Technik AG, which also entered a DPA.
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- Jeffrey P. Naimon to discuss "What to expect: The new administration and regulatory changes" at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference
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- Steven R. vonBerg to discuss "LO comp challenges" at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference
- Michelle L. Rogers to discuss "Major litigation" at the Mortgage Bankers Association Legal Issues and Regulatory Compliance Conference
- Michelle L. Rogers to discuss “The False Claims Act today” at the Federal Bar Association Qui Tam Section Roundtable