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Enforcement Action Dataset

 

Initiation Date:    07/13/2011  Information

Prosecuting Agency:    U.S. Department of Justice

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    N/A

Court:    N/A

Name of Prosecuting Attorneys:   

  • Denis J. McInerney, Chief, Fraud Section, Criminal Division
  • Charles E. Duross, Deputy Chief, Fraud Section, Criminal Division
  • Laura N. Perkins, Trial Attorney, Fraud Section, Criminal Division

US Assisting Agencies:   

  • U.S. Securities and Exchange Commission
  • Federal Bureau of Investigation

Foreign Enforcement Action/Investigation:    Unknown

Foreign Assistance:    Unknown

Origin of the Proceeding:    Voluntary disclosure

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

Armor Holdings, Inc. was a Delaware corporation headquartered in Jacksonville, Florida, whose operating subsidiaries specialized in the manufacture and sale of military, law enforcement, and personnel safety equipment. During the relevant period, the company's common stock was registered with the Commission pursuant to Section 12(b) of the Exchange Act and listed on the New York Stock Exchange and, thus, was an "issuer" pursuant to the FCPA. On July 31,2007, after the conduct described in this Complaint had already occurred, Armor Holdings was acquired by BAE Systems, Inc., an indirect wholly-owned U.S. subsidiary of Britain's BAE Systems PLC. Accordingly, Armor Holdings is no longer registered as an issuer of securities.

Armor Products International, Ltd. ("API") was a wholly owned subsidiary of Armor Holdings, Inc.

From around September 2001 through around 2006, API made corrupt payments through its U.N. Agent to a United Nations procurement official to induce that official to provide non-public, inside information to API, and to cause the U.N. to award body armor contracts to API worth approximately $6 million. API paid the U.N. Agent more than $200,000 in commissions for the 2001 and 2003 U.N. contracts obtained by API, knowing that a portion of that money was to be passed on by the U.N. Agent to a U.N. procurement official. The 2001 and 2003 U.N. body armor contracts resulted in a total profit to API of approximately $1 million.

Also, from around 2001 through June 2007, Armor Holding's Products Group also employed a separate accounting practice that disguised in the books and records of Armor Holdings roughly $4.4 million in commissions paid to third-party intermediaries who brokered the sale of goods to foreign governments.

On July 13, 2011, the DOJ entered into a Non-Prosecution Agreement with Armor Holdings. In the Agreement, Armor accepted its responsibility for the violations of the Anti-Bribery, Books & Records, and Internal Controls provisions of the FCPA. Under the agreement, Armor was required to pay a penalty of $10,290,000 and agreed to implement enhanced compliance programs including an internal monitor to report on compliance to the board of directors and the DOJ for a period of two years.

Separately, in a parallel SEC civil case, without admitting or denying the allegations, Armor Holdings consented to entry of a permanent injunction against further violations and agreed to pay $1,552,306 in disgorgement, $458,438 in prejudgment interest, and a civil money penalty of $3,680,000 as well as the compliance program noted above.

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