According to the company’s admissions, the company knowingly failed to implement internal controls sufficient to ensure that payments from a fund under the control of one of its officers and high-level executives were made for services received and in compliance with Chilean law. Between 2008 and 2015, the company made donations to dozens of foundations controlled by or closely tied to Chilean politicians. During this period, for example, the company funneled approximately $630,000 to foundations controlled by a Chilean official with influence over the government’s mining plans in Chile, a key segment of the company's business.
The company also admitted to falsifying its books and records to conceal payments to vendors associated with politicians, logging them as consulting and professional services the company never received. For example, in 2009, the company paid approximately $11,000 to the sister-in-law of a Chilean official, recording the payment in the company's books as a payment for services received, despite the fact that the official’s sister-in-law submitted the false invoice solely to disguise payment to a Chilean senatorial campaign.
To read the entire DOJ Press Release please follow this link: $15M to Resolve FCPA Charges