The FCPA Report interviewed Manatt's Jacqueline Wolff, co-chair of the firm's Corporate Investigations and White Collar Defense practice, for an article on Louis Berger International's agreement to settle charges with the DOJ for violating the FCPA.
The construction management company had been securing government contracts through deliberately disguised bribes. Bribes were paid over the course of 12 years and high-level executives were involved both in arranging payments and in disguising those payments in the company's books and records.
Wolff told the publication that this is not one of those cases where the government believes there has been an FCPA violation but cannot attribute criminal conduct to anyone within the organization, other than low-level personnel who do not have broad-ranging authority.