On March 15, a former executive of a German engineering company subsidiary, pleaded guilty in the U.S. District Court for the Southern District of New York to conspiracy to violate the Foreign Corrupt Practices Act, including conspiracy to commit bribery, falsify corporate books and records, circumvent internal controls, and commit wire fraud. According to the DOJ press release, the executive “admitted that he and his co-conspirators concealed the illicit payments through various means, including using shell companies associated with intermediaries to disguise and launder the funds.” He was indicted with seven others in 2011.

He was part of a decade-long scheme during which the company paid tens of millions of dollars in bribes to Argentine government officials to secure a contract to create national identity cards. A subsidiary of the company was awarded a contract worth more than $1 billion to provide the ID cards in 1998. The Argentine government ended the project in 2001. Since then, the company and its employees have faced prosecutions and enforcement actions around the world as a result of the bribes and related conduct. The company pleaded guilty in the U.S. to violating the books and records provisions of the FCPA in 2008 for its conduct, and subsidiaries in Argentina and other countries pleaded guilty to similar crimes. The company also paid $350 million to resolve an SEC case and paid a fine of $800 million to resolve charges brought by the Munich Public Prosecutor’s Office.

Prior FCPA Scorecard coverage of the case can be found here, here, here, and here.