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Procurement Insight

Jeffery A. White, C.P.M

President and CEO

April 3, 2019

Gratuities, Kickbacks and Bribery      


IAP Worldwide Services vs. U.S. Department of Justice
June 2015


IAP, a private defense company, agreed to pay $7.1 million to settle criminal charges under the U.S. Foreign Corrupt Practices Act (FCPA). Their VP of Special Projects and Programs plead guilty to FCPA charges. IAP entered into a Non-Prosecution Agreement with the U.S. Department of Justice agreeing to a criminal monetary penalty, reporting obligations, and enhancement of Policy. IAP’s VP plead guilty to charges and was subsequently sentenced. 
The conduct of one employee occurred more than 10 years ago and that individual had left IAP at the time of investigations. One employee can cost a company millions of dollars in penalties. It is critical to educate, as well as train, company management, Procurement Personnel and Non-Procurement employees about the costs of non-compliance.
J.A. White & Associates, Inc. requires that their clients review existing compliance policy and procedures, ensuring that key elements are met:
  • Risk Based Reviews
  • Top Level and Executive Commitment
  • Policies, Procedures and Compliance
  • Education and Training
  • Legal Support
  • Mergers and Acquisitions
  • Monitoring
  • Third Party Relationships

For additional information or training, contact J.A. White & Associates, Inc. Let us help provide your company with a roadmap to FCPA compliance.

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803-407-1399 ext 101
1341 Garner Lane, Suite 104 | Columbia, SC 29210
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