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Nov. 8, 2023

Albemarle Resolutions Bring First Application of DOJ’s Compensation Incentives and Clawbacks Pilot Program

  • Gwen Romack
    Anti-Corruption Report
Albemarle Corporation agreed to pay the DOJ and SEC a combined $218 million in penalties and disgorgement to resolve FCPA offenses related to bribing government officials at state-owned oil refineries around the world. The company also entered into a three-year non-prosecution agreement with the DOJ. Notably, the DOJ determined that the company’s self-disclosure was “not ‘reasonably prompt’” but did allow the company to be the first to benefit from the March 2023 Compensation Incentives and Clawbacks Pilot Program. This article includes insights from Vinson & Elkins, Morrison Foerster and Ropes & Gray on what compliance practitioners can learn from these resolutions. See “Reading the Regulators: Shifts in FCPA Enforcement” (Aug. 16, 2023).

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