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Shell Deferred Prosecution Agreement

The greatest sentences were imposed on Panalpina, Inc. which agreed to pay a total of $83.8 million, including $70.5 million in fines.6 The company was charged with conspiracy to violate the FCPA`s book and registration provisions, and complicity and complicity in violations of the law of its clients.7 PWT was charged with conspiracy to violate and violate fcPA`s anti-corruption provisions. PWT`s charge was resolved as part of the Panalpina agreement concluding a three-year deferred law agreement. 8 Companies have admitted to making these payments in order to avoid customs duties, expedite the importation of equipment, obtain falsified documents, minimize tax rulings, and guarantee other benefits on behalf of their customers10 to pay a $2.5 million fine. “38 conduct regular audits of its internal controls, policies and procedures, submit annual reports to the Fraud Division for three years, and implement a rigorous corporate compliance program.” As part of the Deferred Criminal Prosecutions Agreement, Vitol Inc. and Vitol S.A., another Vitol Group company, agreed to continue to cooperate with the department in ongoing investigations and prosecutions of the conduct. , including by individuals; Improve their compliance programs report to the Division on the implementation of its compliance programs. The resolution stems from Vitol`s plans to pay bribes to officials in Brazil, Ecuador and Mexico. Vitol also agreed to pay more than US$12.7 million to the Commodity Futures Trading Commission (CFTC) in a related case and to pay the CFTC a $16 million fine for business activities not covered by the deferred prosecution agreement with the department. To promote this bribery program, Vitol and his co-conspirators entered into bogus consulting agreements, created shell companies, created fake invoices for alleged consulting services, and used email accounts to transfer funds to offshore companies involved in the conspiracy, and even though they knew the money would be used, at least in part , to pay bribes to Ecuadorian and Mexican officials.

To resolve these investigations, we have concluded five deferred prosecution agreements, a non-prosecution agreement and accepted two convictions; and in this case, no defendant was required to maintain a compliance monitor.

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