The DOJ’s Information charging Siemens in the biggest FCPA enforcement action ever tells of more than 4,000 payments worth at least $1.4 billion to foreign officials to obtain or retain business. Siemens also had systematic and intentional violations of the internal controls and books and records provisions that might have prevented or detected the corrupt payments.
Unfortunately, the DOJ is not charging Siemens under the anti-bribery provisions of the FCPA. This would have barred them as a government contractor.
See:
- Siemens: Systemic Global Corruption by Richard Cassin of the FCPA Blog
- Siemens to Pay Huge Fine in Bribery Inquiry by Mike Esterl and David Crawford of the Wall Street Journal
- DOJ’s Information charging Siemens AG .
- DOJ’s Sentencing Memorandum Against Siemens.
- Joint Statement of DOJ and Siemens on the Iraq Oil for Food Program.
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