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 | Enforcement Action Dataset

Stanford Foreign Corrupt Practices Act Clearinghouse a Collaboration with Sullivan & Cromwell LLP

Enforcement Action Dataset

 
In Re: CDM Smith, Inc. · CDM Smith's Involvement in India between 2011 and 2015

Case Information

In Re: CDM Smith, Inc.

Related FCPA Matter:   CDM Smith's Involvement in India between 2011 and 2015 Information

Case Information

Initiation Date:    06/29/2017  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:   

  • Nicola J. Mrazek, Senior Litigation Counsel, FCPA Unit, Fraud Section, Criminal Division
  • Daniel Kahn, Chief, FCPA Unit, Fraud Section, Criminal Division

US Assisting Agencies:   Unknown

Foreign Enforcement Action/Investigation:   Unknown

Foreign Assisting Agencies:   Unknown

Origin of the Proceeding:    Voluntary disclosure

Whistleblower:    Unknown

Case Status:    Resolved


Summary  Information

CDM Smith, Inc. was a privately held engineering and construction firm incorporated and headquartered in Boston, Massachusetts.

CDM Smith India Private Limited was a wholly-owned subsidiary of CDM Smith in India.

From about 2011 to 2015, employees of CDM Smith’s internal division for Indian operations as well as employees of CDM Smith India paid bribes to officials at the National Highways Authority of India (“NHAI”), which was India’s state-owned highway management agency, as well as to local officials in the Indian state of Goa. Senior management of CDM Smith India approved and participated in the bribery scheme. In all, CDM Smith paid approximately $1.18 million in bribes in India in order to secure contracts for highway construction supervision and design from NHAI and for a separate water project in the state of Goa. These contracts resulted in over $4 million in profits to CDM Smith.

On June 29, 2017, the DOJ issued a declination letter to CDM Smith pursuant to its FCPA Pilot Program. In declining to prosecute CDM Smith, the DOJ cited the company’s voluntary self-disclosure of the misconduct, thorough cooperation, extensive remediation, and agreement to disgorge the profits associated with the misconduct. CDM Smith disgorged just over $4 million.

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