Recent FCPA Enforcement Action
By Timothy L. Dickinson, William F. Pendergast, Jennifer D. Riddle and Paula R. Katz
February 11, 2009, KBR, Inc. (KBR) reached settlements resolving criminal and civil liabilities for violations by its subsidiary Kellogg, Brown & Root LLC (KBR LLC) under the Foreign Corrupt Practices Act (FCPA). The conduct leading to these violations occurred from approximately 1994 to 2004, before KBR became independent in April 2007 from its prior parent, Halliburton Company (Halliburton). Below, we outline the background of the conduct leading to the charges and the settlement terms, as well as a discussion of the unique aspects of this particular FCPA enforcement action.