U.S. based technology firm reserves funds for settlement of FCPA offenses in connection with China sales

November 23 – A U.S. computer software company stated in its securities filing that it had reserved USD 28.2 million in anticipation of a potential settlement with the U.S. Depar tment of Justice (“DOJ”) and U.S. Securities Exchange Commission (“SEC”) for violations of the U.S. Foreign Corrupt Practices Act (“FCPA”) in China. The FCPA investigation relates to payments made for travel and entertainment for employees of Chinese SOEs. The investigation began in May of 2014.

U.K. Serious Fraud Office agrees to first deferred prosecution agreement

November 30 – A London-based bank agreed to a deferred prosecution agreement (“DPA”) with the U.K. Serious Fraud Office (“SFO”) in order to end an investigation into alleged bribes by the bank to Tanzanian government officials. Under the DPA, the bank will pay fines totaling USD 25.2 million as well as USD 7 million in compensation to the Government of Tanzania, and the SFO’s reasonable costs. In addition to the financial penalties imposed, the bank has agreed to continue to cooperate fully with the SFO and submit to an independent review of its existing anti-bribery and corruption controls, policies and procedures.

The SFO worked alongside the DOJ and SEC throughout this process. A separate civil penalty of USD 4.2 million was also imposed on the bank by the SEC.

China and U.S. strengthen cooperation to combat money laundering

December 11 – The China Anti-Money Laundering Monitoring and Analysis Center signed a Memorandum of Understanding with the U.S. Treasury Department’s Financial Crimes Enforcement Network to strengthen cooperation between both nations’ financial intelligence units. This allows for the sharing of information in relation to suspected money laundering cases and terrorist financing in order to prevent offenders abusing either country’s financial systems. According to a press release by the U.S. Treasury Department, this will be extremely valuable in helping thwart illicit activity in the vast and interconnected global economy.