On June 18, 2015, a French court acquitted 14 companies accused of bribery in connection with the U.N. Oil-for-Food program, which operated between 1996 and 2003. The program required that the Iraqi government deposit proceeds from oil sales into a designated U.N. bank account. Further, the program permitted the government to use the funds to buy only food and medicine and other humanitarian goods and services. At issue in this case was the practice of Iraqi government officials to overcharge companies by 10 percent and then deposited the overcharged amount into Iraqi government accounts. Lawyers for the companies, which included Renault Trucks, Schneider Electric and Legrand, successfully argued that no individuals had profited from the Iraqi kickback scheme.

This ruling is consistent with a 2013 case in which another major French company was tried for similar conduct. In that case, the company was acquitted after it was found that “[c]orruption involves the personal enrichment of the corrupt, but in this case it was not proven that any foreign public official or private individual was personally enriched.”

For more details, see the FCPA Blog and Law360