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Construction Industry

As global demand for the design and construction of infrastructure has increased over past decades, especially in high-growth countries like China, companies in the construction industry have entered into record numbers of joint ventures, mergers, acquisitions, consolidations and other partnerships with foreign firms. Demand for greater economies of scale, combined with a growing desire for outside expertise, have added to the cross-border nature of many large-scale projects. For companies involved in such projects, the need to invest in a proactive, world-class compliance program is clear.

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Case Study

Company: JGC Corporation, TSKJ Consortium
Charges: Bribery of government officials

$1.5 billion

JGC Corporation is a Japanese construction and engineering firm that was established in 1928. The company provides services to plants and facilities projects worldwide.

In 2011, JGC was charged with violating the Foreign Corrupt Practices Act through participation in a decade-long scheme to bribe Nigerian government officials in order to obtain engineering, procurement and construction (EPC) contracts. JGC was one of four partners in the TSKJ consortium, which was at the center of the scheme. Together the partners paid $180 million in bribes to Nigerian officials to win contracts. According to court documents, JGC authorized the joint venture to hire two agents to pay bribes to a range of Nigerian government officials to assist JGC and the consortium in obtaining the EPC contracts.

JGC agreed to pay a $218.8 million criminal penalty to resolve the charges. Together, the partners in the TSKJ consortium paid $1.5 billion in penalties. Principal Deputy Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division said, “The approximately $1.5 billion in criminal and civil penalties that have been imposed on the members of the joint venture far exceed their profits from the scheme. Foreign bribery is a serious crime, and as this case makes clear, we are investigating and prosecuting it vigorously.”


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