![]() Back in 2008, Siemens AG had the first billion dollar plus FCPA enforcement action including, among other things, the payment of approximately $2.6 million in bribes to a well-connected business consultant in Mexico, some portion of which allegedly was routed to a senior Pemex official to help the company resolve cost overrun issues related to three refinery modernization projects. Hewlett-Packard Company (HP) had a FCPA enforcement action, partly involving payments the company made to a technology consultant in connection with the sale of HP software packages and licenses to Pemex. ![]() He detailed the software company Paradigm BV which had a FCPA enforcement action based in part on consultant payments, gifts and travel expenses for a Pemex official related to a subcontract it performed on a Pemex project. Nearly six years ago, Matt Ellis writing in CCI, detailed some of the Foreign Corrupt Practices (FCPA) enforcement actions involving Pemex.
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