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 | Enforcement Action Dataset

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

Enforcement Action Dataset

 
United States of America v. Sam P. Wallace Company, Inc. · Sam P. Wallace Company's Involvement in Trinidad and Tobago in 1980

Case Information

United States of America v. Sam P. Wallace Company, Inc.

Related FCPA Matter:   Sam P. Wallace Company's Involvement in Trinidad and Tobago in 1980 Information

Case Information

Initiation Date:    02/23/1983  Information

Prosecuting Agency:    U.S. Department of Justice

Type of Action:    DOJ Criminal Proceeding

Docket or Case Number:    83-cr-0034

Court:    D. Puerto Rico

Name of Prosecuting Attorneys:   

  • Peter B. Clark, Trial Attorney, Fraud Section, Criminal Division
  • Michael L. Fayad, Trial Attorney, 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

Sam P. Wallace Company, Inc. was a Texas corporation with its principal executive offices located in Dallas, Texas. Sam P. Wallace was principally engaged, through wholly-owned subsidiaries, in the construction business in both domestic and international markets, with heavy emphasis on the mechanical contracting portion of that business. The common stock of Sam P. Wallace was at all relevant periods registered with the SEC pursuant to Section 12(b) of the Exchange Act (15 U.S.C. 781(b)) and was listed and traded on the American Stock Exchange.

From about 1980 through about 1981, Sam P. Wallace made payments from Wallace bank accounts of at least $1.391 million to the Chairman of the Trinidad and Tobago Racing Authority, a government agency of the Republic of Trinidad and Tobago, in order to obtain and retain a contract to construct the grandstand and receiving building portion of the Caroni Racetrack Project in Trinidad.

On February 23, 1983, the DOJ filed a four count Information against Sam P. Wallace alleging violations of the Books & Records provision of the FCPA as well as failure to report the export of money. On the same day, Sam P. Wallace pleaded guilty and was ordered to pay a fine of $530,000.

In a parallel action, Sam P. Wallace entered into a Consent Agreement with the SEC that enjoined the company from violating the FCPA and required it to appoint a special committee to investigate and report to the board, court, and SEC on the wrongdoing.

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