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Violation Tracker Individual Record

Company: H.W. Wood Limited
Penalty: $508,000
Year: 2023
Date: November 20, 2023
Offense Group: competition-related offenses
Primary Offense: Foreign Corrupt Practices Act
Secondary Offense: kickbacks and bribery
Violation Description: Tysers Insurance Brokers Limited and H.W. Wood Limited, two U.K.-based reinsurance brokers, agreed to resolve investigations by the Justice Department into violations of the Foreign Corrupt Practices Act (FCPA) arising from their participation in a corrupt scheme to pay bribes to Ecuadorian government officials. Pursuant to its deferred prosecution agreement, H.W. Wood agreed, based on the application of the U.S. Sentencing Guidelines, that the appropriate criminal penalty is $22.5 million and approximately $2.3 million is forfeitable to the United States. However, due to H.W. Wood's financial condition and demonstrated inability to pay the penalty calculated under the U.S. Sentencing Guidelines, H.W. Wood and the department agreed, consistent with the department's inability to pay guidance, that the appropriate criminal penalty is $508,000 and that H.W. Wood is unable to pay the forfeiture amount.
Level of Government: federal
Action Type: agency action
Agency: Justice Department Criminal Division
Civil or Criminal Case: criminal
Prosecution Agreement: deferred prosecution agreement
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Current parent company note: Parent-subsidiary relationship is current as of the most recent revision listed in the Update Log.