DOJ Publishes FCPA Declination on Cross-Border Bribery Investigation

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DOJ recently published an FCPA “declination and disgorgement letter,” its first since August 2020. It has declined to prosecute Jardine Lloyd Thompson Group Holdings Ltd., formerly Jardine Lloyd Thompson Group plc (“JLT”), “despite bribery committed by an employee and agents of the Company and its subsidiaries.” JLT was a UK-based multinational insurance company headquartered in London, England, and was acquired by Marsh & McLennan Companies, Inc. in 2019. It was investigated in connection with bribes paid to Ecuadorian government officials to secure contracts from a state-owned surety company. The stated reasons for DOJ’s declination include its self-disclosure, cooperation, separation from those involved, and agreement to disgorge (over US$29 million).