On January 9, 2014, Alcoa Inc.’s majority-owned and controlled subsidiary, Alcoa World Alumina LLC, pleaded guilty to one count of violating the anti-bribery provision of the FCPA, Information, United States v. Alcoa World Alumina LLC, No. 14-cr-0007 (W.D. Pa. Jan. 9, 2014), and Alcoa Inc. settled a parallel SEC action. In re Alcoa, Inc., Exchange Act Release No. 71,261 (Jan. 9, 2014) (cease and desist orders). The companies admitted that Alcoa World Alumina paid at least $110 million in bribes through a middleman to government officials in Bahrain to obtain $175 million in sales. To resolve both the DOJ and SEC matters, the companies agreed to pay $384 million, comprising a criminal fine of $209 million and an SEC disgorgement judgment for $175 million, against which a $14 million forfeiture to the IRS would be credited. Three features of this enforcement action are particularly noteworthy: (1) the criminal information to which Alcoa World Alumina pleaded guilty did not allege that its employees actually knew that the middleman was paying bribes, but only that they consciously disregarded the fact that the markups were facilitating corrupt payments; (2) the SEC order “makes no findings that any officer, director or employee of Alcoa [Inc.] knowingly engaged in bribery,” but rests Alcoa Inc.’s liability on the theory that its subsidiaries acted as its agents; and (3) the forfeiture to the IRS appears to be a new feature of FCPA settlements.