On March 19, 2014, Japan-based Marubeni Corporation pleaded guilty and agreed to pay an $88 million fine to settle charges that it bribed high-level Indonesian officials in an effort to secure a contract to provide power and energy services. According to the criminal information, Marubeni engaged in a seven-year scheme to pay and conceal bribes to an Indonesian member of parliament and other government officials in order to win a $118 million contract for power-related services.  See Information, United States v. Marubeni Corp., No. 14-cr-00052 (D. Conn. Mar. 19, 2014).  The plea agreement specifically cites Marubeni’s previous lack of an effective compliance program, its failure to remediate the alleged conduct, the lack of a voluntary disclosure, and the company’s initial refusal to cooperate with government investigators. See Plea Agreement, United States v. Marubeni Corp., No. 14-cr-00052 (D. Conn. Mar. 19, 2014). This is the second FCPA matter for Marubeni.  In 2012, the company resolved bribery charges related to a Nigerian natural gas project and agreed to pay $54.6 million as part of a deferred prosecution agreement (“DPA”). The Indonesian scheme pre-dates the settlement of the Nigeria charges.