Transport Logistics’ Inability to Pay a Large Penalty Yields a $2 Million Deal in Russian Corruption Scheme

Maryland-based Transport Logistics International, accused of a long-running bribery scheme involving a Russian official, will only have to pay a $2 million criminal penalty rather than the $21,375,000 penalty that would otherwise be appropriate, according to a deferred prosecution agreement filed by the DOJ in mid-March. The matter, noteworthy because the government, with the help of a forensic accounting expert, conducted an “independent inability to pay analysis” and concluded that a more hefty penalty would jeopardize the continued viability of the company, also signals to small- and mid-sized enterprises that they are not flying under the government’s radar when it comes to anti-corruption enforcement. The Anti-Corruption Report examines what the resolution of this particular Russian collusion means for companies of all sizes. See also “SEC and DOJ Address Corporate Concerns About Future FCPA Enforcement” (Jun. 7, 2017)

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