Colombian Conglomerate Resolves DOJ and SEC FCPA Charges

The DOJ and SEC announced resolutions on August 10, 2023, with Colombian financial conglomerate Grupo Aval and its bank subsidiary, Corporación Financiera Colombiana (Corficolombiana), for violations of the FCPA. The entities agreed to pay over $80 million, an amount that could drop by as much as $20 million under conditions related to resolutions with Colombian authorities, as set out by the DOJ. According to the SEC and the DOJ, between 2012 and 2015, Corficolombiana conspired to pay more than $23 million in bribes to Colombian officials to win the rights to construct and operate a 328‑mile highway project. The Anti-Corruption Report obtained insights from Matteson Ellis, a partner at Miller & Chevalier, about the case and what compliance practitioners can learn from it. See “Deputy Assistant AG Miller Discusses Robust DOJ Anti-Corruption Efforts, Stressing Individual Accountability, Self-Reporting, Remediation and Cooperation” (Mar. 1, 2023).

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