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FCPA Violations

Satisfactory Essays
from 2003 to 2013 made 81 improper payments through commissions to employees of foreign governments or their third-parties. These payments totaled over $9 million, and resulted in more than $34 million in profits. These commissions were approved by senior management at Celcat or Condel, but the real purpose of the payments were concealed from GCC’s executive management.
In September 2012 GCC’s internal audit department performed an audit of financial and operational processes and controls at Condel. In December the audit team sent a report to GCC’s executive management that identified several red flags. The GCC’s executive management began an investigation into Condel and the potential bribery of SOE officials.
In January 2008 to January 2013,
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authorities. GCC provided cooperation with the commission and its staff as the investigation progressed. GCC undertook extensive remediation. This involved terminating or proper disciplinary actions against employees who were involved the violations and improper payments. All of GCC’s executive management during the relevant time period has been replaced. GCC restructured its compliance policies and programs by appointing a chief compliance officer who reports directly to the CEO and audit committee. The restructuring also involved increasing it’s training of sales and accounting employees on policies and compliance expectations, implementing regular third-party reviews of its processes.
GCC entered into a non-prosecution agreement with the U.S. Department of Justice. GCC has acknowledged its responsibility for the conduct relating to the findings of the investigation. The U.S. Department of Justice has ordered GCC to pay a criminal fine of $20,469,694.80 fine as part of settlement. GCC is also paying disgorgement of $51,174,237, and prejudgment interest of $4,107,660 to the commission. A disgorgement is giving up the profits that were obtained by illegal activity. GCC is also required to have follow-up reports and meetings with the commission over the next
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