Corsa Coal Corporation, headquartered in Pennsylvania, mined, processed, and sold metallurgical coal to customers in the domestic and international steel industries.
In a quarterly report issued on November 5, 2020, Corsa Coal disclosed that the company had learned in September 2020 that an overseas third-party sales agent had been charged in an overseas jurisdiction in connection with allegedly unlawful benefits given to a representative of an overseas customer in relation to the sale of coal from operations of U.S. subsidiaries of the Company. The company's board of directors convened a special committee to investigate the allegations, and the committee engaged outside legal counsel to conduct the independent investigation into whether any employees had knowledge or were involved in any activities that could give rise to a violation of anti-corruption laws.
In a quarterly report issued on August 11, 2021, Corsa Coal disclosed that on the basis of findings resulting from its investigation, the company reported the matter to the DOJ and the Royal Canadian Mounted Police, which opened indepedent investigations into the company. Corsa Coal said it was cooperating with these investigations.
Though no charges had been brought against the company at the time, Corsa Coal disclosed in its annual report issued on March 1, 2022, that it had learned that a former employee of the company had pled guilty on November 3, 2021, to conspiracy to violate the FCPA during the period from late 2016 to 2020.
In a quarterly report issued on May 12, 2022, Corsa Coal disclosed that it had learned that a second former employee, who had left the company before commencement of the internal investigation, was charged on March 31, 2022, with conspiracy to violate and direct violations of FCPA as well as related money laundering and wire fraud charges.
On March 8, 2023, the DOJ issued a letter to Corsa pursuant to the agency's FCPA Corporate Enforcement Policy stating that the agency would decline to prosecute the company for violations of the FCPA despite the bribery committed by Corsa's employees, and on March 9, the company issued a press release stating that the Canadian Royal Mounted Police had concluded its investigation with no further action.
