Glenn S. Leon, Chief, Fraud Section, Criminal Division
Natalie R. Kanerva, Trial Attorney, Fraud Section, Criminal Division
Jonathan P. Robell, Assistant Chief, Fraud Section, Criminal Division
Daniel M. Gitner, Chief, Criminal Division
David Felton, Assistant United States Attorney
Jessica Feinstein, Special Assistant U.S. Attorney
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
The Boston Consulting Group, Inc. (BCG) was a global management consulting firm based in Boston.
According to the documents in this case, between 2011 and 2017, BCG, through its Portugal office, paid an Angolan agent in Angola approximately $4.3 million in commissions to help BCG obtain business with agencies of the Angolan Government, including the Ministry of Economy and the National Bank of Angola, despite certain BCG employees in Portugal being aware that the agent had close ties to Angolan Government officials and members of the ruling political party. BCG’s agent shared a portion of the commissions with Angolan government officials associated with the Ministry of Economy in order to help BCG obtain its contracts in the country. Certain BCG employees in Portugal took steps to conceal the nature of the agent’s work for BCG when internal questions arose, including by backdating contracts and falsifying the agent’s purported work product. In all, BCG secured eleven contracts with the Ministry of Economy and one with the National Bank, from which it earned approximately $22.5 million in revenues and $14.424 million in profits.
On August 24, 2024, the DOJ issued a letter pursuant to the agency's FCPA Corporate Enforcement Policy to BCG declining to prosecute the company despite the bribery committed in Angola. Under the terms of the declination, BCG agreed to disgorge the ill-gotten profits of $14,424,000. The DOJ determined that a declination was appropriate given the company's timely self-disclosure of the misconduct, its full and proactive cooperation, and the appropriate remediation it conducted, including the termination of employees in Portugal involved in the misconduct and requiring them to give up their equity in the company in addition to other compensation-based penalties.
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