In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary resources. This month we ask: Which company received the first declination under the Department of Justice’s (DOJ) new FCPA Corporate Enforcement Policy? How is the International Monetary Fund (IMF) “stepping up” its efforts to combat corruption? What new remedy has China proposed to recover the proceeds of corruption? The answers to these questions and more are here in our April 2018 Top Ten list.

1. New Jersey-based Data and Analytics Firm Resolves China FCPA Allegations with SEC, Receives First Declination Under DOJ FCPA Corporate Enforcement Policy. On April 23, 2018, the Securities and Exchange Commission (SEC) announced that Dun & Bradstreet had agreed to pay more than $9 million, including a $2 million civil penalty, to resolve FCPA accounting provision violations stemming from allegedly improper payments made by two of its Chinese subsidiaries to third parties and government officials in order to obtain non-public financial statement information and non-public personal data in violation of Chinese law. According to the administrative cease‑and‑desist order, the improper payments were falsely recorded as legitimate business expenses. On the same day, DOJ sent the company a letter stating that the Department had “declined prosecution consistent with the FCPA Corporate Enforcement Policy.” Notably, this is the first public declination citing the Policy, which was announced in November 2017 and replaced the FCPA Pilot Program. The letter stated that, despite having concluded that bribery had occurred, DOJ chose to decline based on a number of factors, including the company’s (1) identification of the misconduct, (2) prompt voluntary self-disclosure, (3) thorough corporate investigation, (4) full cooperation, (5) enhanced compliance program and internal accounting controls, (6) remediation, which included termination of all employees involved in the misconduct, and (7) disgorgement paid to SEC.

2. Luxembourg-based Telecommunications Company Announces DOJ Declination. On April 24, 2018, Millicom stated that DOJ had informed the company that it was closing its investigation into potential improper payments made on behalf of the company’s joint venture in Guatemala. According to the release, Millicom voluntarily reported the potential improper payments to DOJ in October 2015. Millicom had also reported to Swedish authorities. In a May 9, 2016 press release, Millicom disclosed that the Swedish prosecutor had notified Millicom that it had discontinued its preliminary investigation due to a lack of jurisdiction.

3. Connecticut-based Industrial Conglomerate Discloses DOJ Declination. In an April 27, 2018 securities filing, United Technologies Corporation disclosed that DOJ had dropped its probe into alleged FCPA violations in China. The filing also noted that the company was in talks with SEC about a potential resolution. In December 2013 and January 2014, the company voluntarily disclosed to DOJ, SEC, and the U.K. Serious Fraud Office (SFO) that it was conducting an internal investigation into potential FCPA violations in connection with a non-employee sales representative’s sale of jet engines manufactured by its subsidiaries.

4. World Bank Debars Kenya-based Railroad Company. On April 16, 2018, the World Bank announced the debarment of Africa Railways Logistics Limited (ARLL) for two years in connection with an employee’s alleged attempt to improperly influence the customs and port clearance process for locomotives on two projects in Kenya and Uganda. This was the first debarment related to an investment by the International Finance Corporation (IFC), the private-sector arm of the World Bank. The debarment, which renders ARLL ineligible to participate in World Bank-financed projects, is part of a settlement agreement in which the company acknowledged responsibility for the underlying conduct and agreed to specified corporate compliance requirements as a condition for release from debarment. Related companies Africa Railways Limited and Rift Valley Railways Kenya Limited were sanctioned with conditional non-debarment, which allows them to remain eligible to participate in World Bank projects, so long as they comply with their settlement agreement obligations. According to the World Bank, the companies benefitted from a reduced period of debarment in light of their cooperation and voluntary remedial actions.

5. New Guilty Pleas in Long-Running Bribery Prosecutions.

  • Chinese-born Executive Pleads Guilty in United Nations Bribery Case. On April 4, 2018, more than two years after she was arrested, Chinese-born executive Julia Vivi Wang pleaded guilty in the Southern District of New York to FCPA and tax charges related to a bribe allegedly paid to John Ashe, the former president of the United Nations General Assembly. Wang was a background figure in the trial of Chinese real estate billionaire Ng Lap Seng, whom a jury convicted in July 2017 of bribing Ashe and Francis Lorenzo, formerly the U.N. ambassador from the Dominican Republic. Wang admitted to helping her husband, former Ng ally Forest Cao, pay $500,000 to Ashe in exchange for assistance with Cao’s business interests. Both Ashe and Cao have since passed away.
  • Venezuelan Official Pleads Guilty to Money Laundering in Venezuela Bribery Prosecution. On April 19, 2018, DOJ announced that Cesar David Rincon Godoy (Cesar Rincon), a former general manager of the procurement subsidiary of Venezuela’s state-owned and state-controlled energy company, Petroleos de Venezuela S.A. (PDVSA), had pleaded guilty in the Southern District of Texas to money laundering for his role in an alleged scheme involving payments by U.S.-based companies to Venezuelan government officials to improperly obtain energy contracts and priority payment for outstanding invoices. The charges against Cesar Rincon were announced in February 2018. According to admissions in his plea, Cesar Rincon conspired with four co-defendants and others, all of whom were then-current officials at PDVSA or former officials of other Venezuelan government agencies or instrumentalities, to solicit vendors for bribes and kickbacks in exchange for aiding the vendors with their PDVSA business. Cesar Rincon admitted to conspiring with others to launder over $7 million in proceeds from the various bribery schemes in which he was involved. To date, eleven individuals have pleaded guilty in connection with this investigation. The court accepted Cesar Rincon’s guilty plea and imposed a personal money judgment in the amount of $7,033,504.71; Cesar Rincon agreed to the entry of an order of forfeiture. Sentencing is scheduled for July 9, 2018.

6. Aruban Official and Florida-based Telecom Executive Plead Guilty in Connection with Bribery Scheme. On April 13, 2018, DOJ announced that Egbert Yvan Ferdinand Koolman, a former official of Aruban state-owned Servicio di Telecommunicacion di Aruba N.V. (Setar), had pleaded guilty in the Southern District of Florida to one count of conspiracy to commit money laundering in connection with $1.3 million in bribe payments he received from individuals and companies located in the United States and abroad in exchange for using his position at Setar to award lucrative mobile phone and accessory contracts. According to his guilty plea, the bribe payments were either made in the United States or from bank accounts located in the United States. DOJ simultaneously announced that Lawrence W. Parker, Jr., the owner of five Florida-based telecommunications companies, had pleaded guilty in December 2017 to conspiracy to violate the FCPA and to commit wire fraud in connection with the scheme to bribe Koolman. On April 30, 2018, Parker was sentenced to 35 months in prison and ordered to pay over $700,000 in restitution. Koolman’s sentencing is scheduled for June 27, 2018.

7. Ecuadorean Official Pleads Guilty in Connection with Bribery Scheme. On April 11, 2018, Marcelo Reyes Lopez, a former official of Ecuador’s national oil company, PetroEcuador, pleaded guilty in the Southern District of Florida to one count of conspiracy to commit money laundering. According to reports, Reyes was a contracts executive with PetroEcuador and allegedly accepted bribes in exchange for the awarding of contracts. The indictment alleges that, from 2013‑2016, Reyes conspired to launder the proceeds of violations of the FCPA and Ecuador’s public corruption statute.

8. Japan-based Electronics Company and U.S.-based Subsidiary Resolve FCPA Allegations. On April 30, 2018, DOJ and SEC announced that Panasonic Corporation and one of its subsidiaries had agreed to pay a combined $280 million to resolve allegations regarding payments to an employee of an unnamed state‑owned airline. Pursuant to a deferred prosecution agreement filed in federal court in the District of Columbia, the subsidiary agreed to pay a $137.4 million criminal penalty and to retain an independent compliance monitor for two years, followed by an additional year of self-reporting. Pursuant to an administrative cease‑and‑desist order alleging books and records and other violations, the parent agreed to pay approximately $143 million in disgorgement and prejudgment interest to SEC.

9. IMF “Steps Up” Engagement on Governance and Corruption. On April 22, 2018, the IMF announced that its Executive Board had endorsed a new framework for “stepping up” engagement on governance and corruption in its member countries. According to empirical findings in an IMF policy paper, a high level of corruption is associated with significantly lower growth, investment, FDI, and tax revenues. For instance, the paper found that falling from the 50th to the 25th percentile in a corruption index can correlate with a GDP per capita growth rate drop of half a percentage point or more. The report also showed that corruption and poor governance are associated with higher inequality and lower inclusive growth. In light of this, IMF revisited its governance policy, in place since 1997, and adopted the new framework, which includes several steps: (1) developing a clear and transparent methodology for assessing the nature and severity of governance weaknesses; (2) assessing and providing recommendations to address the economic impact of identified weaknesses; (3) assessing the criminalization and prosecution of foreign bribery offenses by member countries (according to the IMF, all G7 nations plus Austria and the Czech Republic have agreed to this assessment); and (4) emphasizing assessment and discussion of governance and corruption in surveillance and lending programs.

10. China Proposes Default Judgments for Certain Corruption Offenses. On April 25, 2018, China’s state news agency announced that China plans to introduce default judgments in corruption‑related criminal cases for individuals who have fled overseas. As we have noted previously, China has prioritized the repatriation of Chinese kleptocrats and kleptocracy funds over the last several years. (See, for example, our April 2015, November 2016, and March 2017 Top Tens.) According to a government white paper cited by Xinhua News, from 2014 to mid-October 2017, 3,453 fugitives were brought back to the country from more than 90 countries and regions and illegal assets worth 9.5 billion yuan (around $1.5 billion) were recovered. The draft revision to the Criminal Procedure law providing for default judgments has been submitted to the legislature for review.

By MoFo’s FCPA and Global Anti-Corruption Team

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary resources. This month we ask: Will the Department of Justice (DOJ) FCPA Pilot Program continue past its one year expiration date? How did the UK, Finland, and Argentina fare in the latest OECD Working Group on Bribery’s assessment of their foreign bribery enforcement records? What major domestic corruption efforts are underway in Argentina, Brazil, China, South Korea, and Thailand? The answers to these questions and more are here in our March 2017 Top Ten list.

1. FCPA Pilot Program to Continue Past April 2017.

During his March 10, 2017, keynote address to the American Bar Association’s 31st Annual National Institute on White Collar Crime, Kenneth Blanco, Acting Assistant Attorney General of DOJ’s Criminal Division, addressed the future of the FCPA Pilot Program. Announced in April 2016, the Pilot Program provides that companies which voluntarily disclose improper conduct to the Fraud Section’s FCPA Unit, fully cooperate in accordance with the Principles of Federal Prosecution of Business Organizations and the Yates Memo, appropriately remediate, and otherwise pass muster under the “stringent requirements” of the Program may receive up to a 50% reduction off the bottom of the U.S. Sentencing Guidelines fine range and generally will not be required to retain an independent compliance monitor. According to Blanco, the Program “provides our prosecutors, companies and the public clear metrics for what constitutes voluntary self-disclosure, full cooperation and full remediation. It also outlines the benefits that are accorded a voluntary self-disclosure of wrongdoing, full cooperation and remediation.” Blanco said of the Program, which was set to expire on April 5, 2017, “we will begin the process of evaluating [its] utility and efficacy . . . , whether to extend it, and what revisions, if any, we should make to it.” Blanco stated that the Program “will continue in full force until we reach a final decision on those issues.” In addition to discussing the Pilot Program, Blanco touted the Criminal Division’s cross-border investigative efforts, including the Division’s cooperation with its foreign law enforcement counterparts. According to Blanco, “the Criminal Division’s approach to large, complex transnational and white collar investigations is truly global in nature and the results that we have obtained demonstrate and reinforce the importance of working with and maintaining true partnerships with our counterparts aboard.” With respect to FCPA enforcement, Blanco continued the new administration’s theme of emphasizing the importance of multinational anti-bribery enforcement “to create an even playing field for global business.”

2. TRACE Reports Significant Increase in Global Foreign Bribery Enforcement.

On March 2, 2017, Trace International released its annual Global Enforcement Report (GER 2016). The GER 2016, a review of international anti-bribery enforcement trends in 2016, found that U.S. enforcement actions doubled (from 15 to 30), while non-U.S. enforcement actions more than doubled (from 4 to 10) since 2015. The GER 2016 noted that the U.S. Securities and Exchange Commission (SEC) and DOJ conducted 198 foreign bribery investigations, of which 38% involved companies headquartered outside the United States or individuals with non-U.S. citizenship. Of the investigations concerning alleged bribery of foreign officials being conducted against non-U.S. companies and individuals, the highest number involved companies or individuals in the United Kingdom, followed by Switzerland and Germany. Government officials in the Asia Pacific region were the alleged recipients of bribes in approximately 46% of investigations and 40% of enforcement actions concerning alleged bribery by U.S. companies and individuals. While SEC is conducting more anti-bribery investigations into U.S. companies and individuals than DOJ, the inverse is true for non-U.S. companies and individuals.

3. Second Circuit Hears Oral Argument in Challenge to DOJ’s Position on Jurisdictional Reach of FCPA.

On March 2, 2017, the United States Court of Appeals for the Second Circuit heard oral argument in an interlocutory appeal arising out of the prosecution of former Alstom SA executive Lawrence Hoskins, a case that raises questions about the jurisdictional reach of the FCPA. The issue before the Second Circuit, as expressed in DOJ’s brief, is “[w]hether a foreign person (who does not reside in the United States) can be liable for conspiring or aiding and abetting a U.S. company to violate the Foreign Corrupt Practices Act if that individual is not in the categories of principal persons covered in the statute.” As set out in documents such as the FCPA Resource Guide, DOJ’s position for years has been that foreign nationals and companies “may . . . be liable for conspiring to violate the FCPA . . . even if they are not, or could not be, independently charged with a substantive FCPA violation.” Hoskins, a UK citizen working for an Alstom subsidiary in France, was charged with conspiring with Alstom’s subsidiary in Connecticut and others to violate the FCPA by paying bribes to officials in Indonesia in exchange for a lucrative power station project contract. An August 2015 ruling by Connecticut U.S. District Judge Janet Arterton rejected DOJ’s position, holding that a nonresident foreign national who is not an agent of a domestic concern and commits no acts while physically present in the territory of the United States is excluded from FCPA substantive liability and, therefore, also cannot be charged with conspiring to violate the FCPA or with aiding and abetting an FCPA violation. At the Second Circuit hearing, Hoskins argued that Congress intended that the FCPA should exclude certain types of individuals from direct liability and that, pursuant to the 1932 Supreme Court ruling in Gebardi v. United States, an individual who could not be held directly liable under a given statute could not be charged with violating that same statute. Hoskins asserted that DOJ had other avenues it could use to reach conduct of non-resident foreign nationals, e.g., via the money laundering statute. Senior Judge Gerard Lynch seemed skeptical of Hoskins’ position and presented Hoskins with numerous hypotheticals, many of which got to the issue of why Congress would allow prosecutors to charge a “rickshaw driver in Jakarta” with an FCPA violation but not a Paris or London-based executive who instructed the driver to carry out the illegal act. The implication, Lynch noted—echoing an argument made by DOJ—was that this would simply incentivize U.S. companies to act indirectly, via their non-U.S. employees, instead of directly hiring the fixer in a given country where a bribery scheme is carried out. As we noted in August 2015, the outcome of the Hoskins decision is a case to watch because it is critical to many of DOJ’s enforcement principles.

4. Two More Telecom Executives Settle FCPA Claims with SEC.

In March 2017, the remaining two defendants in the long-running Magyar Telekom Plc case—Elek Straub and Andras Balogh—agreed to resolve civil FCPA charges brought against them by SEC in 2011. SEC disclosed the fact, but not the details, of the agreed settlements in two letters to Southern District of New York Judge Richard J. Sullivan. Straub and Balogh had been scheduled to go to trial in May 2017 with co-defendant Tamas Morvai, who agreed to settle with SEC in February 2017. According to the SEC complaint, the three defendants violated the FCPA by authorizing €4.875 million in bribes to Macedonian officials in 2005 and 2006 to prevent the introduction of a competitor to the Macedonian telecommunications market and to receive other regulatory benefits. In September 2016, Judge Sullivan rejected the defendants’ claim that SEC had failed to allege a sufficient jurisdictional nexus for the charges, ruling that the defendants’ actions in connection with Magyar’s EDGAR filings satisfied the FCPA’s jurisdictional requirements.

5. Aviation Services Company Owner Latest to Be Sentenced for Mexican Bribery Scheme.

On March 30, 2017, Douglas Ray, the president and owner of Houston-based airplane maintenance and repair company Global Aviation Services was sentenced in the Southern District of Texas to 18 months in prison (plus three years of supervised release) and $590,000 in restitution for his role in a $2 million scheme to bribe Mexican officials in exchange for repair and maintenance contracts. Ray is one of six individuals—four Texas business people and two Mexican officials—charged in the case. In October 2016, Ray and Victor Hugo Valdez Pinon, one of the Mexican officials, pleaded guilty to the charges of conspiracy to violate the FCPA and conspiracy to commit wire fraud. In February 2017, Hunt Pan Am Aviation executives Daniel Perez and Kamta Ramnarine were each sentenced to three years’ probation after pleading guilty to having conspired to violate the FCPA. In January 2017, one of the Mexican officials, Ernesto Hernandez-Montemayor, was sentenced to 24 months in prison for his role in the scheme. Montemayor had pleaded guilty to one count of conspiracy to commit money laundering and admitted that he received bribes from the Texas business people in exchange for assisting them with winning contracts from his employer, and that he conspired with the four business people to launder the bribe proceeds.

6. OECD Working Group on Bribery Releases Its First Ever Phase 4 Reports, Focusing on the UK and Finland.

On March 23, 2017, the Organisation for Economic Co-operation and Development (OECD) Working Group on Bribery released its first reports as part of Phase 4 of the OECD Anti-Bribery Convention’s peer-review monitoring system, to which all parties to the Convention are subject. The Phase 4 monitoring process, launched in March 2016, focuses on the evaluated country’s enforcement of the OECD Anti-Bribery Convention and considers the country’s particular challenges and positive achievements. UK and Finland were the subjects of these reports.

  • With respect to the UK, the Working Group found that foreign bribery enforcement has increased significantly since the UK’s Phase 3 evaluation in March 2012, notably due to the efforts of the Serious Fraud Office (SFO). But the Working Group also found that “persistent uncertainty” about the SFO’s existence and budget is “harmful” and called for the UK to maintain the role of the SFO in foreign bribery cases. The Working Group also recommended that the UK further improve interagency cooperation and ensure effective measures are in place to safeguard the independence of investigations and prosecutions.
  • With respect to Finland, the Working Group found that the country has a “discouragingly high” acquittal rate in foreign bribery cases, noting that although Finland has effectively detected and investigated foreign bribery allegations, each of the five cases of Finnish individuals or companies paying bribes to foreign public officials since 1999 that have progressed to prosecution has resulted in the acquittal of all parties for foreign bribery. The Working Group recommended that Finland (1) assign foreign bribery cases to courts or judges with specialized skills and experience, (2) provide detailed information and training to judges, prosecutors, and investigators on the foreign bribery offense and its application, and (3) enact clear and comprehensive legislation to protect whistleblowers.

In accordance with the monitoring process, the UK and Finland will submit written follow-up reports within two years to the Working Group on steps taken to implement its recommendations.

7. OECD Working Group on Bribery Criticizes Argentina’s Foreign Bribery Record, While Former President Ordered to Stand Trial on Financial Mismanagement Charges.

On March 24, 2017, the OECD Working Group on Bribery released a supplemental report on Argentina’s implementation of the OECD Anti-Bribery Convention, finding that Argentina “remains in serious non-compliance” with key articles of the Convention. The report is the result of the Working Group’s “exceptional” decision in 2014 to conduct a supplemental evaluation of Argentina following the country’s Phase 3 evaluation. In the latest report, the Working Group found that Argentina still cannot hold companies liable for foreign bribery or prosecute its citizens who commit foreign bribery abroad and recommended that Argentina ensure a Corporate Liability Bill that was introduced to Congress in October 2016 addresses these and other deficiencies, such as the absence of corporate liability for corruption-related false accounting, inadequate fines and sanctions, and lack of protection for whistleblowers. The Working Group also found that Argentina needs to address concerns about judicial and prosecutorial independence in the enforcement of its foreign bribery laws.

Separately, on March 23, 2017, a judge in Argentina ruled that former president Cristina Kirchner should stand trial on charges of financial mismanagement. The former economy minister and the former head of the Central Bank have also been charged, and another twelve defendants face trial as alleged accomplices. Kirchner is facing separate investigations into alleged corruption and, in December 2016, another judge approved her trial for alleged illicit association and administrative fraud in connection with infrastructure projects awarded to a company owned by a close associate. Kirchner’s vice president is currently being tried for corruption.

8. Former Officials from Thailand and Brazil Sentenced to Lengthy Terms of Imprisonment on Corruption Charges.

  • Former Thai Tourism Official Sentenced to 50 Years’ Imprisonment. On March 29, 2017, Juthamas Siriwan, the former governor of the Tourism Authority of Thailand, was sentenced by a Thai court to 50 years in prison in connection with a bribery scheme involving Thailand’s annual film festival. In 2009, after a trial in the Central District of California, two U.S. film executives, Gerald and Patricia Green, were found guilty of conspiring to violate the FCPA and to commit money laundering for paying bribes to Siriwan and her daughter to obtain and retain the festival’s management contract between 2003 and 2006. Siriwan successfully resisted extradition to the U.S. to face money laundering conspiracy charges but, in August 2015, a Thai investigative committee recommended she be indicted in Thailand for her role in the bribery scheme. Siriwan and her daughter Jittisopa, who was also found guilty and sentenced to 44 years in prison, are required to repay the $1.81 million that the Thai court found they received from the Greens.
  • Former Brazil House Speaker Sentenced to 15 Years’ Imprisonment. On March 30, 2017, Eduardo Cunha, the former speaker of Brazil’s lower legislative house, was sentenced to more than 15 years in prison in connection with the “Operation Car Wash” investigation into alleged corruption at Brazil’s state-owned oil company, Petróleo Brasileiro S.A. (“Petrobras”). A federal court in Brazil found Cunha guilty of corruption, money laundering, and illegally sending money abroad, including receiving bribes during Petrobras’ acquisition of a Benin oil field in 2011, making him the highest profile politician to be convicted as a result of the investigation. Cunha led the impeachment proceedings that ousted Brazilian President Dilma Rouseff last year, but he was forced from his position as speaker in July 2016, expelled from Congress in September 2016, and arrested on corruption charges in October 2016. His case was heard by Judge Sergio Moro, who has been a leading figure in the Car Wash investigation, which has led to charges against more than two hundred people. On the day of Cunha’s conviction, federal prosecutors separately announced they are seeking 2.3 billion reais (approximately $731 million) from Brazil’s Progressive Party, accusing the party of the civil crime of “misconduct in political office” for bribes its members allegedly received as part of the Petrobras scheme.

9. Former South Korean President Arrested in Corruption Investigation.

On March 31, 2017, South Korea’s former president, Park Geun-hye, was arrested on charges including bribery and abuse of power in connection with a corruption scandal that led to her impeachment in December 2016. Park lost her immunity from prosecution when South Korea’s Constitutional Court upheld her impeachment on March 10, 2017. A court in Seoul ordered her arrest following a hearing on March 30, 2017, and state prosecutors can detain her for up to twenty days for questioning before formally charging her. Park is being held at the same detention center as Choi Soon-sil, with whom Park is accused of colluding to pressure companies for tens of millions of dollars in return for political favors, and Lee Jae-yong, the acting head of Samsung who is accused of giving or promising to give Choi $37 million to obtain government support for a merger of two Samsung units. Choi and Lee are being tried separately.

10. Chinese Authorities Report on Efforts to Crack Down on Corruption.

On March 7, 2017, Chinese authorities reportedly announced the launch of operation “Sky Net 2017” to track down corruption suspects who have fled abroad and recover their illicit gains. According to China’s Central Commission for Discipline Inspection (CCDI), efforts to capture corrupt fugitives, including Sky Net, led to the return of 2,566 fugitives from more than 70 countries and regions between early 2014 and the end of last year and the confiscation of 8.64 billion yuan in illegal assets. An operation targeting fugitives implicated in dereliction of duty cases, launched in October 2014, has led to the return of 164 suspects from 37 countries and regions, according to a report from China’s Supreme People’s Procuratorate (SPP) released in March 2017.

According to a report from China’s Supreme People’s Court (SPC) released on March 12, 2017, China’s court system heard 45,000 graft cases involving 63,000 people, which represents a roughly one-third rise from the figures reported in 2015. The defendants included 35 former officials at the provincial and ministerial level or above, and 240 former officials at the prefectural level. Courts at all levels convicted 2,862 people of bribery. The SPP reported that prosecution proceedings were launched against 48 former officials in 2016 at the provincial and ministerial level or above, and procurators investigated 17,410 lower level officials suspected of corruption.