On July 2, 2009, Siemens AG (“Siemens”) reached a settlement with the World Bank Group in connection with an investigation by the World Bank into corruption involving a project undertaken in Russia by a Siemens subsidiary. The settlement includes a commitment by Siemens to pay $100,000,000 over the next 15 years, an agreement that the Siemens’ Russian subsidiary would be deferred for a five year period, and a “voluntary two-year shut-out” from bidding on World Bank business for Siemens AG and all of its consolidated subsidiaries and affiliates.45

The $100,000,000 in payments by Siemens are to be used to support global efforts to combat fraud and corruption, including providing funds to organizations and projects aimed at attacking corruption through collective action, training and education. The World Bank explained that portions of this monetary “commitment” will also be directed to assisting governments in the recovery of assets stolen by corrupt leaders, and strengthening efforts to identify and crack-down on corrupt practices. The World Bank will have audit rights over the use of these funds and veto rights over the selection of anti-corruption groups or programs receiving funds.

This settlement by Siemens follows its multiple recent record settlements with the Department, the SEC and German authorities.46