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
” (Oct. 9, 2013).