22 Arrested in Largest-Ever FCPA Case Against Individuals
By Christopher M. Matthews | January 19, 2022 6:32 pm

Lanny Breuer, Assistant Attorney General for the Criminal Division (photo by Ryan J. Reilly / Main Justice).

Assistant Attorney General Lanny A. Breuer announced Tuesday that 22 individuals were arrested on Monday for violations of the Foreign Corrupt Practices Act (FCPA), the largest single investigation and prosecution against individuals in the 32-plus year history of the law.

The arrests of the 22 defendants, executives and employees of companies in the military and law enforcement products industry, stemmed from an FBI undercover operation.

“This ongoing investigation is the first large-scale use of undercover law enforcement techniques to uncover FCPA violations and the largest action ever undertaken by the Justice Department against individuals for FCPA violations,” Breuer said in a news release. The FCPA prohibits U.S. persons and companies, and foreign persons and companies acting in the United States, from bribing foreign government officials for the purpose of obtaining or retaining business.

The defendants were charged in U.S. District Court in Washington on Dec. 11. Their indictments were unsealed on Monday. The companies that the individuals worked for were not indicted, and Breuer would not say if further charges were coming.

Twenty-one of the defendants were arrested in Las Vegas, where they were attending the Shot Show, the largest trade show for professionals involved with the shooting sports and hunting industries, according to the show’s Web site. One defendant was arrested in Miami. The defendants worked for 13 U.S. firms located in eight states, as well for as two companies based in the United Kingdom and one in Israel.

“As one person in my office said earlier today, this is one case where what happened in Vegas doesn’t stay in Vegas,” Breuer said at a pen-and-pad session with reporters to announce the arrests.

The indictments allege that over two and a half years, the defendants were led to believe they were involved in a bribery scheme to acquire a $15 million contract from the minister of defense of an unnamed African country to outfit the country’s presidential guard. The contracts were for a number of products, including tear-gas grenade launchers, M4 rifles, bullet-proof vests and handguns.

The defendants allegedly agreed to pay a 20 percent bribe to a sales agent supposedly representing the defense minister. In reality, the sales agent was an undercover FBI agent.

“From now on, would-be FCPA violators should stop and ponder whether the person they are trying to bribe might really be a federal agent,” said Breuer, who heads DOJ’s Criminal Division.

Breuer would not identify the African country from which the minister was purportedly from, but did say the country was not involved in the investigation.

Assistant Director Kevin Perkins of of the FBI’s criminal Investigative Division said the investigation was the “first of its kind,” but added that the FBI was prepared to use undercover techniques in future FCPA cases.

“[This investigation] demonstrates the FBI’s intention to use every investigative technique at our disposal to obtain the best possible evidence,” Perkins said. “Every tool in the tool chest is fair game in an FCPA investigation.”

Joseph Warin, chairman of the litigation department for Gibson, Dunn & Crutcher’s Washington office, said the use of undercover techniques in this case was a substantive development for FCPA enforcement. “The most salient thing about this is how deep the undercover operation was,” Warin said. “What distinguishes this from the vast majority of FCPA cases is that there’s usually no undercover operation.”

Warin said that other DOJ enforcement areas, such as organized crime and anti-trust, employ undercover investigations regularly. He characterized today’s news as a “coming of age” for FCPA enforcement.


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