On January 9, Alcoa World Alumina LLC, a majority-owned and controlled global alumina sales company of Alcoa Inc., agreed to plead guilty and to pay $223 million in criminal fines and forfeitures to resolve charges that it paid millions of dollars in bribes through an international middleman in London to officials of the Kingdom of Bahrain, in violation of the Foreign Corrupt Practices Act (FCPA). According to the acting head of the Justice Department’s Criminal Division, Mythili Raman, the company admitted to “involvement in a corrupt international underworld in which a middleman, secretly held offshore bank accounts, and shell companies were used to funnel bribes to government officials to secure business.”

Alcoa agreed to plead guilty to one count of violating the anti-bribery provisions of the FCPA in connection with a 2004 corrupt transaction, to pay a criminal fine of $209 million and to administratively forfeit $14 million. As part of the plea agreement, Alcoa Inc. must also implement and maintain an anti-corruption compliance program. Alcoa concurrently settled civil charges with the Securities and Exchange Commission in an administrative proceeding related to the anti-bribery, internal controls, and books and records provisions of the FCPA, and will pay an additional $161 million in disgorgement.   

This case marks the fourth-largest overall FCPA settlement with the federal government behind Siemens ($800 million on December 15, 2008), KBR & Halliburton ($579 million on February 11, 2009) and Total S.A. ($398.2 million on May 29, 2013).