Alstom S.A. ("Alstom") was headquartered in France. Alstom was in the business of designing, constructing, and providing services related to power generation facilities, power grids, and rail transportation systems around the world. Alstom Network Schweiz AG, formerly Alstom Prom AG ("Alstom PROM"), was a subsidiary of Alstom that was headquartered in Switzerland. Alstom PROM was responsible for overseeing compliance as it related to Alstom's consultancy agreements for many of Alstom's power sector subsidiaries.
From approximately 1999 to 2011, Alstom PROM and other Alstom entities bid on various power projects with state-owned and state-controlled companies in Indonesia, Saudi Arabia, Egypt, and the Bahamas. In order to obtain and retain business, Alstom PROM along with other Alstom entities paid bribes to government officials. The bribes were made through consultants who passed on all or some of the money to officials who had the ability to influence the award of the contracts. As a result of the bribes, Alstom PROM and other Alstom entities were awarded contracts in Indonesia, Saudi Arabia, Egypt, and the Bahamas valued at approximately $3,508,000,000.
On December 22, 2014, the DOJ filed an Information against Alstom Network Schweiz, charging the company with violating the anti-bribery provisions of the FCPA. At the same time, Alstom Network Schweiz entered into a plea agreement with the DOJ. On November 25, 2015, the court sentenced Alstom Network Schweiz and ordered it to pay a mandatory assessment of $400. No additional fine was imposed because of the $772,290,000 fine entered against Alstom in a related action was for overlapping conduct.
