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Foreign Corrupt Practices Act & Anti-Corruption


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  • Former Vice President of Defense Contractor Jailed for Bribing Kuwaiti Officials

    On October 9, James Rama, a former Vice President of Florida-based defense contractor IAP Worldwide Services, Inc., was sentenced in the U.S. District Court for the Eastern District of Virginia to 120 days in prison for conspiracy to violate the anti-bribery provisions of the FCPA.  Rama pleaded guilty to the conspiracy charge on June 16 for his role in a scheme by IAP to pay more than $1.7 million in bribes to Kuwaiti officials to win a government contract intended to provide nationwide surveillance capabilities for several Kuwaiti government agencies.  Rama had faced a recommended sentence under the Sentencing Guidelines of between 57 and 60 months, but received a substantially shorter sentence in part due to his cooperation with authorities during their investigation.  Prosecutors had recommended that Rama received a one year sentence, while the defense had requested just supervised release.  IAP previously? entered into a non-prosecution agreement with the DOJ and agreed to pay $7.1 million to resolve the allegations against the company.

    IAP Worldwide Services James Rama

  • U.S. Defense Contractor Settles FCPA Action for $7.1 Million

    On June 16, the DOJ announced that a U.S. defense contractor, IAP Worldwide Services, Inc., will pay $7.1 million to resolve allegations that the company made over $1.7 million in illegal payments to Kuwati officials through a third party.  The company entered into a non-prosecution agreement that requires the company to implement an enhanced compliance program and internal controls designed to prevent and detect FCPA violations, and to report annually for three years to DOJ regarding its compliance program.  A former Vice President of IAP, James Rama, also pleaded guilty to one count of conspiracy to violate the anti-bribery provisions of the FCPA. The DOJ emphasized the company’s cooperation with the government’s investigation as relevant to the decision to enter into a non-prosecution agreement instead of a more harsh resolution.  This statement appears to implement the policy announced in recent DOJ speeches, which have touted the benefits of cooperation to companies including the possibility of non-prosecution agreements.   It is worth noting that an individual executive still was required to plead guilty, regardless of the company’s resolution.

    NPA IAP Worldwide Services