Marsh & McLennan Companies, Inc. ("Marsh") is a global professional services firm in the areas of risk, strategy and people. The Company conducts business through two segments: Risk and Insurance Services, which includes risk management activities as well as insurance and reinsurance broking and services; and Consulting, which includes health, wealth and career services and products, and specialized management, economic and brand consulting services. On April 1, 2019, Marsh acquired all of the outstanding shares of Jardine Lloyd Thompson Group plc, an insurance company based in England. Once acquired, the company was reorganized as Jardine Lloyd Thompson Group Holdings Ltd. Both iterations of the company will be referred to as "JLT."
According to the documents in this case, the DOJ found evidence that, between 2014 and 2016, JLT's employees and agents paid approximately $10,800,000 to a Florida-based third-party intermediary that the employees and agents knew would be used, in part, to pay approximately $3,157,000 in bribes to Ecuadorian government officials in order to obtain contracts with Seguros Sucre S.A., the Ecuadorian state-owned and -controlled insurance company. Approximately $1.2 million of these bribe payments were laundered through and into bank accounts in the United States.
On March 18, 2022, the DOJ issued a letter to JLT pursuant to the agency's FCPA Corporate Enforcement Policy declining to prosecute the company for violations of the FCPA. In the letter, the DOJ noted the company's voluntary self-disclosure of the misconduct, its comprehensive cooperation and remediation, and the full disgorgement of the profits derived from the bribery scheme. Under the terms of the letter, JLT agreed to disgorge $29,081,951 to the U.K. Serious Fraud Office, and the DOJ credited the full amount for what was owed to the agency.
