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ARTICLE · 30 JUNE 2015

Government Contracting Abroad: Beware Compliance Risks

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In 2004, Kuwait's Ministry of Interior (MOI) initiated a project called the Kuwait Security Program to develop a national surveillance program using closed-circuit television.

United StatesGovernment, Public Sector
Fatema Merchant
Fatema Merchant
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On June 16, 2015, IAP Worldwide Services Inc., a private defense and government contracting company, agreed to pay $7.1 million to settle criminal charges of the U.S. Foreign Corrupt Practices Act (FCPA) related to bribing Kuwaiti government officials to secure a Kuwaiti government contract.  On the same day, James Michael Rama, IAP's Former Vice President of Special Projects and Programs also pleaded guilty to FCPA charges.  For U.S. government contractors, the opportunities to provide services and expertise to foreign governments are lucrative, but this enforcement action also highlights the risks associated with obtaining such contracts.

Background

In 2004, Kuwait's Ministry of Interior (MOI) initiated a project called the Kuwait Security Program to develop a national surveillance program using closed-circuit television. The program was divided into two phases.  Phase I was the planning and feasibility phase preceding the more lucrative Phase II installation

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