Control Components, Incorporated ("CCI") was a Delaware corporation headquartered in Rancho Santa Margarita, California, that designed and manufactured control valves for use in the nuclear, oil and gas, and power generation industries worldwide. CCI's state-owned customers included, but were not limited to, Jiangsu Nuclear Power Corporation (China) ("JNPC"), Guohua Electric Power (China), China Petroleum Materials and Equipment Corporation ("CPMEC"), PetroChina, Dongfang Electric Corporation (China), China National Offshore Oil Company ("CNOOC"), Korea Hydro and Nuclear Power ("KHNP"), Petronas (Malaysia), and National Petroleum Construction Company (United Arab Emirates) ("NPCC").
From around 2003 through around 2007, defendant CCI made approximately $4.9 million in corrupt payments to officers and employees of state-owned customers and derived approximately $31.7 million in net profits from sales related to those payments. From around 2003 through around 2007, defendant CCI made approximately $1.95 million in corrupt payments to officers and employees of privately-owned customers and derived approximately $14.82 million in net profits from sales related to those payments. In total, from around 2003 through around 2007, defendant CCI made approximately 236 corrupt payments to officers and employees of state-owned and private companies in thirty-six countries totaling approximately $6.85 million and earned approximately $46.5 million in net profits from the sales related to those corrupt payments.
On July 22, 2009, the DOJ filed a two count Information in the Central District of California against CCI alleging conspiracy to violate the Travel Act and the anti-bribery provisions of the FCPA as well as substantive violations of the anti-bribery provisions of the FCPA. On the same date, CCI entered into a plea agreement with the DOJ. Under the terms of the agreement, CCI agreed to pay a fine of $18.2 million plus a mandatory assessment of $1200, to continue to implement and enhance its anti-corruption compliance programs, and to hire an independent monitor for a period of 3 years. The fine represented a significant departure from the minimum stipulated by the sentencing guidelines and was agreed to by the DOJ because of CCI's substantial cooperation and remediation in the matter.