In the DOJ’s first corporate FCPA settlement action of 2015, Florida-based defense and government contracting company IAP Worldwide Services, Inc. has agreed to pay $7.1 million in four installments to resolve charges it conspired to bribe Kuwaiti officials, through an intermediary, in exchange for a contract to build a homeland surveillance system. The company admitted the charges in a non-prosecution agreement and the primary employee involved, James Michael Rama, pled guilty. The DOJ cited IAP’s cooperation as a factor for entering into the NPA. See “Prosecutors and Defense Lawyers Discuss FCPA Risk Areas, Government Expectations and the Length of Investigations” (May 27, 2015).