Albemarle FCPA Enforcement Action – Overview

FCPA Compliance Report

Welcome to the award-winning FCPA Compliance Report, the longest-running podcast in compliance. Today, we begin a short podcast series on the Albemarle FCPA enforcement action. Today, we open with Matt Kelly, providing an overview.

The intriguing case of Albemarle, a chemicals company embroiled in a bribery scheme, is a stark reminder of the importance of compliance and timely remediation measures. Albemarle faced hefty fines and penalties, totaling over $218 million, for using intermediaries to sell chemicals to state-owned oil companies and funnel bribes to government officials. However, the company’s swift action in withholding bonuses during their internal investigation and implementing remedial measures, such as eliminating sales agents and adopting a direct sales approach, was recognized and credited.

We underscore the significance of Albemarle’s transformation of its business model as a positive remediation measure that effectively reduces corruption risk. We also emphasize the importance of timely self-disclosure and the benefits of initiating remediation measures before an investigation is complete. The fines and penalties imposed on Albemarle are among the largest FCPA settlements in 2023. Join us in this FCPA Compliance Report podcast episode as we dive deeply into the regulatory outcome, remediation efforts, and compliance lessons from Albemarle’s case.

Key Highlights:

• Bribery Scheme with “Friend” Emails
• Identifying and Addressing Control Gaps for Ethical Business Practices
• FCPA Settlement and Corruption Risk Reduction

Resources:

Tom Fox blog post series on the Albemarle FCPA Enforcement Action.

Tom Fox

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