Marubeni Corp. Pleads Guilty to FCPA Bribery Charges
Client Memorandum

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On March 19, 2014, the U.S. Department of Justice announced that Tokyo-based trading company Marubeni Corporation had entered a guilty plea and will pay a criminal fine of $88 million in connection with violations of the U.S. Foreign Corrupt Practices Act. This is one of multiple FCPA-based resolutions announced by a Japanese company in the last three years alone, and continues several recent trends in FCPA enforcement. Marubeni is not an “issuer” within the meaning of the FCPA and, accordingly, there was no parallel enforcement action brought by the U.S. Securities and Exchange Commission.