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Business Crimes BulletinColumns & DepartmentsLitigationWhite Collar Crime

In the Courts

By Colleen Snow
March 01, 2019

New Charges in Insurance Corporation of Barbados Limited Bribery Case

The Department of Justice's (DOJ) investigation into Insurance Corporation of Barbados Limited (ICBL) for violations of the Foreign Corrupt Practices Act (FCPA) ended with an Aug. 23, 2018 declination. According to the published declination, the DOJ identified $36,000 in bribes paid by ICBL agents and employees between August 2015 and April 2016 to a Barbadian government official in exchange for insurance contracts. Donville Inniss — then-member of the Parliament of Barbados and the Minister of Industry, International Business, Commerce, and Small Business Development of Barbados — was paid bribes to ensure that ICBL was awarded two government insurance contracts. Inniss then hid the ICBL bribe money by laundering it through a United States dental office that belonged to his friend. The money flowed through a New York bank account in the name of his friend to a Florida bank account in Inniss's name.

The ICBL declination was the first under the DOJ's November 2017 Corporate Enforcement Policy, which “provid[es] additional benefits to companies based on their corporate behavior once they learn of misconduct,” including a declination when the company satisfies voluntary self-disclosure, full cooperation, and timeline and appropriate remediation. In its declination letter, the DOJ noted ICBL's timely self-disclosure; comprehensive internal investigation; cooperation with the government's investigation; compliance program enhancements; remediation, including terminating ICBL executives/employees involved in the scheme; and identification of culpable employees such that DOJ could pursue and charge these individuals. Pursuant to the Corporate Enforcement Policy, ICBL was required to disgorge $93,940.19, the profits illegally earned as a result of the bribery scheme.

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