$384 Million Alcoa Civil and Criminal FCPA Settlement Highlights the Risks of Third-Party Relationships

Alcoa World Alumina LLC, a majority-owned and controlled sales company of Alcoa, Inc., a global provider of primary aluminum and fabricated aluminum, has resolved criminal and civil charges that it violated the FCPA.  The $384 million settlement, resolved via a plea agreement and SEC cease and desist order, is one of the largest in FCPA enforcement history.  It involves a decades-long scheme in which a third party – a company Alcoa hired to facilitate sales of alumina to a Bahraini aluminum smelter – used middlemen and shell companies to funnel $110 million to Bahraini foreign officials to secure business for Alcoa.  See “Sample Questions to Ask Third Parties When Initiating Anti-Corruption Due Diligence,” The FCPA Report, Vol. 2, No. 20 (Oct. 9, 2013).

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