China Port Official Bribes, False Container Certification Bribes, China Export Bribes, and Other Illegal Payments Can Be The Basis of Large Whistleblower Reward Lawsuits That Can Pay Large Financial Rewards to Professionals Who Properly and Anonymously Expose Significant and Systematic Foreign Corrupt Practices Act Violations Including Bribes and Accounting Fraud by China International Trade Illegal Kickback Whistleblower Reward Lawyer, China False Container Certification Bribe Lawyer, and China Port Official Bribe Lawyer Jason S. Coomer
China is the largest exporter in the world and the second largest importer in the world. Through a modernized system of ports and transport system, the People's Republic of China controls a large part of the world's globalized production lines. Unfortunately this government control is subject to bribes and government corruption that inhibit free trade and allow port officials, customs agents, and other Chinese government officials to demand bribes, illegal kickbacks, and other illicit payments from companies doing business in China and through Chinese ports. Through the Foreign Corrupt Practices Act (FCPA) and SEC Rewards Program, whistleblowers are encouraged to step up and confidentially report bribery schemes and illegal kickbacks surrounding Chinese ports, imports, exports, and other international trade. Under new whistleblower protections, these Chinese whistleblowers and multinational corporation whistleblowers can receive large financial rewards for being the first to properly expose significant government corruption.
If you are aware of international bribery schemes, illegal kickbacks, or other illicit payments regarding Chinese international trade, please feel free to contact Chinese Port Official Bribe Whistleblower Lawyer, China Customs Agent Bribe Lawyer, and Chinese International Business Illegal Bribe Whistleblower Reward Lawyer Jason Coomer via e-mail message or use our submission form to have a foreign corrupt practices act attorney review a potential Chinese Port Official Bribe Whistleblower Lawsuit, Chinese Import Bribe Whistleblower Reward Lawsuit, Foreign Corrupt Practices Act Violation Whistleblower Reward Lawsuit, or other Foreign Corruption Practices Act Securities and Exchange Commission Bounty Action.
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There is a worldwide effort by the international community to crack down on government corruption, illegal kickbacks, and illegal bribes in international trade and prevent corruption costs from increasing the costs of imports and exports. This effort includes initiatives by the United States to identify and prosecute complicated and systematic illegal bribery schemes involving and illicit payments to government officials. To identify hard to detect international bribery schemes, the United States Securities Exchange Commission is offering large bounties (whistleblower rewards) for persons with specialized knowledge of systematic bribes and complicated bribery schemes. These large economic incentives are designed to encourage import export experts, customs experts, logistics experts, and other persons aware of complicated international bribery schemes, import kickbacks, export illegal bribes, and other international trade government fraud to step up and become a confidential import export bribe whistleblower, customs fraud whistleblower, logistics whistleblower, and other international trade whistleblower.
The United States Bounty Actions are set up under the Foreign Corrupt Practices Act (FCPA). The FCPA applies to “issuers” (U.S. and foreign companies listed on U.S. securities exchanges and their employees); “domestic concerns,” which run the gamut of business entities organized under U.S. laws or with their principal place of business in the United States; the officers, directors, employees, and agents of those U.S. business entities (irrespective of nationality); U.S. citizens; U.S. resident aliens; “any person,” including all foreign persons, who commit an act in furtherance of a foreign bribe while in the United States, and U.S. businesses and nationals acting abroad. A Company must require all of its affiliated companies and all of their employees to comply with the Foreign Corrupt Practices Act.
As such, complicated international bribery scheme that are run through subsidiaries, joint venture partners, contractors, foreign banks, and other agents can be subject to these bounty actions including disgorgement of the illicit payment benefits.
Modernization of Chinese Ports & Distribution Systems has Greatly Expanded China's Ability to Import and Export Goods as well as Develop Manufacturing Industries
Modern innovations in logistics, computer technology, communications, and ports have led to a rapid expansion in international trade and the globalization of manufacturing and supply chains. China has utilized this increase in international trade and globalization of production and consumption to expand its economy and emerge into an economic superpower. Through advances in logistics and the modernization of Chinese ports, China has been able to increase its imports and exports as well as become an integral part of the production supply chains of many products. These advances include structural changes in inter-port relations and port-hinterland relationships. Through logistics China has strengthened the role its ports play as nodes within the global transport system. Historically ports were measured on their ability to accommodate ships and other modes of transport effectively and efficiently. Contemporary developments in transportation, however, dictate that emphasis has shifted to the ability of ports to fulfill new roles in the logistics era within the context of operating as part of an integrated global supply chain system.
The role of modern seaports involves integration into the supply chain. The port is considered as part of a cluster of organizations in which different logistics and transport operators are involved in bringing value to the final consumers. In order to be successful, such channels need to achieve a high degree of coordination and cooperation. The determination of the parameters that encompass the extent of integration of ports/terminals in global supply chains has, therefore, become of great importance for ports.
China has not only modernized its port system, but also has built industries around the ports to manufacture and transport goods for international trade. Bringing supplies through imports adding value to the products through manufacturing then exporting the products. The Chinese import and export network is formed around three major harbor areas: 1) The Bohai Sea area of northern China (including Beijing) is serviced by the ports of Tianjin, Dalian and Yantai; 2) the Yangtze River Delta area includes the ports of Shanghai and Ningbo; and 3) the Pearl River Delta in southern China includes the ports of Shenzhen, Guangzhou and Hong Kong. These ports have experienced tremendous growth and expansion over the last decade and have helped China increase its international trade.
To help develop Chinese ports, the Chinese government has encouraged foreign direct investment into port modernization programs. By bringing in foreign investments including resources and technology, the Chinese government has been able to successfully expand international trade including imports and exports. Through liberalization of foreign investment restrictions in the modernization of Chinese ports, the Chinese ministries have been able to improve international trade and port logistics including in the areas of transportation, freight forwarding, storage, warehousing, and port management.
China's largest and busiest ports include Port of Hong Kong, Port Shanghai, Port of Shenzhen, Port of Guangzhou, Port of Qingdao, Port of Dalian, Port of Lüshunkou, Port of Jiuzhou, Port of Suzhou, Port of Xiamen, Port of Ningbo, and Port of Tianjin. This thriving network of Chinese ports have seen modernization and logistical technology used to greatly increase China's ability to import and export goods leading to economic prosperity.
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The Port of Hong Kong is a deepwater seaport that is located by the South China Sea. It is one of the busiest ports in the world and is an economic gateway to mainland China. The Port of Hong Kong is one of several hub ports serving the South-East and East Asia region and has high traffic of containerized manufactured products. The Port of Hong Kong set a record in its container throughput in 2007 by handling 23.9 million TEUs (20-foot equivalent units of containers), maintaining its status as the largest container port serving southern China and one of the busiest ports in the world. Some 456,000 vessels arrived in and departed from Hong Kong during the year, carrying 243 million tons of cargo and about 25 million passengers. A key factor in the economic development of Hong Kong include its natural shelter and deep waters that provide ideal conditions for berthing and handling all types of vessels. It is one of the busiest ports in the world, in the three categories of shipping movements, cargo handled and passengers carried.
The Port of Hong Kong has utilized port modernization programs including foreign investments to enhance container security initiatives and to facilitate China’s WTO compliance with regard to Customs procedures and expanded distribution rights. Though the Port of Hong Kong is still one of the world's busiest container ports, it is facing increasing competition from other south China ports. Marine Department of the Hong Kong Special Administrative Region (SAR) is the administrator of the Hong Kong port. Its principal functions are to ensure safe operation of the port and all Hong Kong waters as well as to operate the Hong Kong Shipping Register and safeguard the quality of the Hong Kong registered ships.
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The Port of Shanghai is situated at the middle of the 18,000km-long Chinese coastline, where the Yangtse River, known as “the Golden Waterway”, flows into the sea. It is the leading port in the T-shaped waterway network composed by the Yangtse River and the coastline, and is also China’s largest comprehensive port and one of the country’s most important gateways for foreign trade. It is faced towards the northern and southern coastal seas of China and the oceans of the world, and is linked with the Yangtse River and the inland waterways of Yangtse River Valley region such as Jiangsu, Zhejiang and Anhui provinces etc. Expressway and state-level highways lead the Port to the national highway network to all regions of the country.
The Port of Shanghai has recently undergone major renovation and expansion that include numerous railway connections and the development of logistics systems for inland barging. Therefore in addition to the advantageous geographical location and favorable natural conditions of the Port of Shanghai, the port has an expanded distribution capacity and it connected to a vast economically developed hinterlands. This developed inland distribution infrastructure and facilities allows the Port of Shanghai to serve the vast hinterland in the Yangtse River Delta and the entire Yangtse River valley. The Yangtse River Delta is home to a cluster of cities which are the most economically vibrant area in China. The Jianghan Plain and Sichuan Basin are areas that are densely populated and have a developed agriculture and a strong industrial base. These areas will prove to be the powerhouse for the sustainable growth of the Port of Shanghai. The annual import and export trade through Shanghai, in terms of value, accounts for a quarter of China’s total foreign trade. The Port’s container throughput in 2010 reached 29.069 million TEUs, ranking it the largest container port in the world.
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The Port of Shenzhen is one of the busiest and fastest growing ports in southern mainland China. It is located in the southern region of the Pearl River Delta in China's Guangdong province. It is the economic hinterland for Hong Kong trade with the Mainland and also one of the most important port in terms of China's international trade. The port is home to 39 shipping companies whom have launched 131 international container routes. There are 560 ships on call at Shenzhen port on a monthly basis and also 21 feeder routes to other ports in the Pearl River Delta region.
Shenzhen was considered a small town when it was chosen as China’s first special economic zone to pilot the country’s reform and opening-up drive 22 years ago. It is now one of China’s richest cities. Shenzhen has invested heavily in developing its logistics industry including building logistics parks that provide international logistics services.
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Port of Guangzhou is the main seaport of Guangzhou city in the Guangdong province, China. The port is operated by Guangzhou Port Group Co. Ltd which is a state owned company. The company was established on February 26, 2004 from the former Guangzhou Harbor Bureau. It was approved by the Guangzhou Municipal Government. It is currently the largest comprehensive port in South China. Its international maritime trade reaches over 300 ports in more than 80 countries and districts worldwide. The port also incorporates the former Huangpu Port. The Port of Guangzhou is situated at the intersection of the three most important rivers of Dongjiang, Xijiang and Beijiang in South China. All the three rivers have the waterway, railway, expressway and air lines intersecting here, thus forming a critical transportation hub. It is the main port of focus in the Pearl River Delta Region.
The port's harbor area extends along the Pearl River coast and water areas in the cities of Guangzhou, Dongguan, Zhongshan, Shenzhen and Zhuhai. The port being situated beyond the entrance of Pearl River opening serve as a gateway for shipping activity for other Harbor area such as Nansha Harbor Area, Xinsha Harbor Area, Huangpu Harbor Area and Inner Harbor Area, and Nansha Harbor Area near Hong Kong.
Qingdao port was founded in 1892 and is the largest commercial port in Shandong province. Its primary export cargoes are coal and crude oil. Its major imports include metal ores, grain, steel, timber and fertilizers. The port accommodates, on average, more than 1,000 vessels per month, with an annual freight traffic capacity of 84 million tons. Recently, Qingdao port completed construction of China’s largest container, crude oil and ore wharves. TIANJIN Tianjin port is the fourth largest in China and serves as an outlet for goods from the central and western parts of China. As the leading port in north China, it plans to allocate $1.4 billion to build infrastructure projects over the coming decade. The development proposal includes work on a deep-water channel to accommodate 150,000 dead weight ton (dwt) ships and a man-made island covering an area of 30 square kilometers. These projects are to be completed by 2005.
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The Foreign Corrupt Practices Act (FCPA) prohibits bribery of foreign officials by U.S. companies and foreign companies listed on the U.S. securities exchange. The Foreign Corrupt Practices Act (FCPA) also requires such companies to maintain accurate books and records. Foreign Corrupt Practices Act Whistleblowers that properly report violations of the Foreign Corrupt Practice Act by a U.S. or foreign companies listed on the U.S. securities exchanges can recover a large reward for exposing Foreign Corrupt Practices Act (FCPA) violations.
Chinese whistleblowers, multinational corporation employee whistleblowers, and other persons with evidence of Chinese government official corruption can work confidentially through Foreign Corrupt Practices Act violation lawyers to expose government corruption and recovery large financial rewards for reporting the illegal conduct. By exposing and preventing government corruption in China, the whistleblower will be able to help the Chinese economy as a whole, improve the flow of foreign direct investment into China, and benefit the Chinese people.
Evidence of government corruption will usually include proof of illegal payments, accounting information, bank statements, video, e-mail messages, contracts, and false certifications. Further, these corruption scams can often be very sophisticated and include multiple companies through joint ventures and subsidiaries. Typically a combination of evidence and insider knowledge is needed to expose the government corruption.
WASHINGTON – Daimler AG, a German corporation, and three of its subsidiaries have resolved charges related to a Foreign Corrupt Practices Act (FCPA) investigation into the company’s worldwide sales practices, the Department of Justice announced today.
At a hearing today before U.S. District Court Judge Richard J. Leon in the District of Columbia, Daimler AG’s Russian subsidiary DaimlerChrysler Automotive Russia SAO (DCAR), now known as Mercedes-Benz Russia SAO, and its German subsidiary, Export and Trade Finance GmbH (ETF), each pleaded guilty to criminal informations charging the companies with one count of conspiracy to violate the anti-bribery provisions of the FCPA and one count of violating those provisions. As part of the plea agreements, DCAR and ETF agreed to pay criminal fines of $27.26 million and $29.12 million, respectively.
Daimler AG entered into a deferred prosecution agreement and agreed to the filing of a criminal information charging that company with one count of conspiracy to violate the books and records provisions of the FCPA and one count of violating those provisions. Daimler AG’s Chinese subsidiary DaimlerChrysler China Ltd. (DCCL), now known as Daimler North East Asia Ltd., also entered into a deferred prosecution agreement and agreed to the filing of a criminal information charging it with one count of conspiracy to violate the anti-bribery provisions of the FCPA and one count of violating those provisions. In total, Daimler AG and its subsidiaries will pay $93.6 million in criminal fines and penalties.
According to court documents, Daimler AG, whose shares trade on multiple exchanges in the United States, engaged in a long-standing practice of paying bribes to foreign government officials through a variety of mechanisms, including the use of corporate ledger accounts known internally as “third-party accounts” or “TPAs,” corporate “cash desks,” offshore bank accounts, deceptive pricing arrangements and third-party intermediaries. According to court documents, Daimler AG and its subsidiaries made hundreds of improper payments worth tens of millions of dollars to foreign officials in at least 22 countries – including China, Croatia, Egypt, Greece, Hungary, Indonesia, Iraq, Ivory Coast, Latvia, Nigeria, Russia, Serbia and Montenegro, Thailand, Turkey, Turkmenistan, Uzbekistan, Vietnam and others – to assist in securing contracts with government customers for the purchase of Daimler vehicles. The contracts were valued at hundreds of millions of dollars. In some cases, Daimler AG or its subsidiaries wire transferred these improper payments to U.S. bank accounts or to the foreign bank accounts of U.S. shell companies, in order for those entities to pass on the bribes. Within Daimler AG and its subsidiaries, bribe payments were often identified and recorded as “commissions,” “special discounts,” and/or “nützliche Aufwendungen” or “N.A.” payments, which translates to “useful payment” or “necessary payment,” and was understood by certain Daimler employees to mean “official bribe.” According to court documents, certain corrupt payments continued as late as January 2008, after the Department of Justice had begun its investigation. In all cases, Daimler AG improperly recorded these corrupt payments in its corporate books and records. Daimler AG admitted that it earned more than $50 million in profits from corrupt transactions with a nexus to the territory of the United States. Daimler AG also admitted that it agreed to pay kickbacks to the former Iraqi government in connection with contracts to sell vehicles to Iraq under the U.N.’s Oil for Food program.
“In a decade-long scheme involving tens of millions of dollars, Daimler AG and three of its subsidiaries brazenly offered bribes in exchange for business around the world,” said Principal Deputy Assistant Attorney General Mythili Raman of the Criminal Division. “Using offshore bank accounts, third-party agents and deceptive pricing practices, these companies saw foreign bribery as a way of doing business. The guilty pleas and deferred prosecution agreements entered today by Daimler AG and its subsidiaries should serve as a message to other companies subject to the FCPA and conducting business around the world that corrupt business is bad business.”
In connection with its guilty plea, DCAR admitted that it made improper payments to Russian federal and municipal government officials to secure contracts to sell vehicles by over-invoicing the customer and paying the excess amount back to the government officials, or to other designated third parties that provided no legitimate services to DCAR or Daimler AG. When requested, DCAR or Daimler AG employees caused the wire transfer of payments from Daimler AG’s bank accounts in Germany to, among other destinations, U.S. and Latvian bank accounts held by shell companies with the understanding that the money, in whole or in part, was for the benefit of Russian government officials.
In connection with its guilty plea, ETF admitted that it made corrupt payments directly to Croatian government officials and to third parties, including two U.S.-based corporate entities, with the understanding that the payments would be passed on, in whole or in part, to Croatian government officials, to assist in securing the sale of 210 fire trucks.
In connection with its deferred prosecution agreement, DCCL admitted that it made improper payments in the form of commissions, delegation travel, and gifts for the benefit of Chinese government officials or their designees in connection with sales of commercial vehicles and Unimogs to various Chinese government customers. DCCL admitted that in certain cases it used U.S.-based agents to facilitate the bribe payments.
Under the terms of its deferred prosecution agreement, Daimler AG agreed to retain an independent compliance monitor for a three-year period to oversee the company’s continued implementation and maintenance of an FCPA compliance program, and to make reports to the company and the Department of Justice. DCAR, ETF and DCCL are covered by the monitoring provisions of the deferred prosecution agreement with their parent company Daimler AG. Daimler AG also agreed to fully cooperate with investigations by U.S. and foreign authorities of the company’s corrupt payments.
Today, Judge Leon also entered a separate judgment against Daimler AG resolving a related civil complaint filed by the U.S. Securities and Exchange Commission (SEC). Daimler AG agreed to pay $91.4 million in disgorgement of profits relating to those violations.
SEC Charges Siemens AG for Engaging in Worldwide Bribery FOR IMMEDIATE RELEASE 2008-294
Washington, D.C., Dec. 15, 2008 — The Securities and Exchange Commission today announced an unprecedented settlement with Siemens AG to resolve SEC charges that the Munich, Germany-based manufacturer of industrial and consumer products violated the Foreign Corrupt Practices Act (FCPA) by engaging in a systematic practice of paying bribes to foreign government officials to obtain business. Additional Materials
Litigation Release No. 20829 SEC Complaint
The SEC alleges that Siemens paid bribes on such widespread transactions as the design and construction of metro transit lines in Venezuela, power plants in Israel, and refineries in Mexico. Siemens also used bribes to obtain such business as developing mobile telephone networks in Bangladesh, national identity cards in Argentina, and medical devices in Vietnam, China, and Russia. According to the SEC's complaint, Siemens also paid kickbacks to Iraqi ministries in connection with sales of power stations and equipment to Iraq under the United Nations Oil for Food Program. Siemens earned more than $1.1 billion in profits on these and several other transactions.
Siemens has agreed to pay $350 million in disgorgement to settle the SEC's charges, and a $450 million fine to the U.S. Department of Justice to settle criminal charges. Siemens also will pay a fine of approximately $569 million to the Office of the Prosecutor General in Munich, to whom the company previously paid an approximately $285 million fine in October 2007.
"Public companies that bribe foreign officials are confronting an increasingly well-coordinated international law enforcement effort," said SEC Chairman Christopher Cox. "The SEC has brought a record number of enforcement actions for foreign bribery during the past two years, and heightened international cooperation has been critical to those successful efforts. Seimens paid staggering amounts of money to circumvent the rules and gain business. Now, they will pay for it with the largest settlement in the history of the Foreign Corrupt Practices Act since it became law in 1977."
Linda Chatman Thomsen, Director of the SEC's Division of Enforcement, said, "This pattern of bribery by Siemens was unprecedented in scale and geographic reach. The corruption alleged in the SEC's complaint involved more than $1.4 billion in bribes to government officials in Asia, Africa, Europe, the Middle East, and the Americas. Our success in bringing the company to justice is a testament to the close, coordinated working relationship among the SEC, the U.S. Department of Justice, and international law enforcement, particularly the Office of the Prosecutor General in Munich."
Cheryl J. Scarboro, an Associate Director in the SEC's Division of Enforcement, said, "The day is past when multi-national corporations could regard illicit payments to foreign officials as simply another cost of doing business. The $1.6 billion in combined sanctions that Siemens will pay in the U.S. and Germany should make clear that these corrupt business practices will be rooted out wherever they take place, and the sanctions for them will be severe."
The SEC's complaint alleges that between March 12, 2001, and Sept. 30, 2007, Siemens created elaborate payment schemes to conceal the nature of its corrupt payments, and the company's inadequate internal controls allowed the conduct to flourish. Siemens made thousands of payments to third parties in ways that obscured the purpose for, and the ultimate recipients of, the money. Employees obtained large amounts of cash from cash desks, which were sometimes transported in suitcases across international borders for bribery. The authorizations for payments were placed on post-it notes and later removed to eradicate any permanent record. Siemens used numerous slush funds, off-books accounts maintained at unconsolidated entities, and a system of business consultants and intermediaries to facilitate the corrupt payments. Siemens made at least 4,283 payments, totaling approximately $1.4 billion, to bribe government officials in return for business to Siemens around the world. In addition, Siemens made approximately 1,185 separate payments to third parties totaling approximately $391 million, which were not properly controlled and were used, at least in part, for such illicit purposes as commercial bribery and embezzlement.
The misconduct involved employees at all levels, including former senior management, and revealed a corporate culture long at odds with the FCPA. The SEC's complaint alleges that despite the company's knowledge of bribery at two of its largest groups — Communications and Power Generation — the tone at the top at Siemens was inconsistent with an effective FCPA compliance program and created a corporate culture in which bribery was tolerated and even rewarded at the highest levels of the company. In November 2006, Siemens' current management began to implement reforms to the company's internal controls, which substantially reduced, but did not entirely eliminate, corrupt payments. All but $27.5 million of the corrupt payments occurred before Nov. 15, 2006.
Siemens violated Section 30A of the Securities Exchange Act of 1934 (Exchange Act) by making illicit payments to foreign government officials in order to obtain or retain business. Siemens violated Section 13(b)(2)(B) of the Exchange Act by failing to have adequate internal controls to detect and prevent the payments. Siemens violated Section 13(b)(2)(A) of the Exchange Act by improperly recording the payments in its books and records.
Without admitting or denying the SEC's allegations, Siemens has consented to the entry of a court order permanently enjoining it from future violations of Sections 30A, 13(b)(2)(A), and 13(b)(2)(B) of the Exchange Act; ordering it to pay $350 million in disgorgement of wrongful profits, which does not include profits factored into Munich's fine; and ordering it to comply with certain undertakings regarding its FCPA compliance program, including an independent monitor for a period of four years. Since being approached by SEC staff, Siemens has cooperated fully with the ongoing investigation. Siemens' massive internal investigation and lower level employee amnesty program was essential in gathering facts regarding the full extent of Siemens' FCPA violations.
The SEC acknowledges the assistance of the U.S. Department of Justice, Fraud Section; the U.S. Attorney's Office for the District of Columbia, Fraud and Public Corruption Section; the Federal Bureau of Investigation; the Internal Revenue Service; the Office of the Prosecutor General in Munich, Germany; the U.K. Financial Services Authority; and the Hong Kong Securities and Futures Commission.
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As an United States International Bribery Scheme Whistleblower Reward Lawyer and United States Foreign Corrupt Practices Act Illicit Payment Whistleblower Reward Lawyer, Jason S. Coomer commonly works with other powerful illegal international business bribe whistleblower reward lawyers and illegal contract kickback whistleblower lawyers to handle large international bribery lawsuits, international trade government corruption lawsuits, and other Foreign Corrupt Practices Act Whistleblower Reward Lawsuits. He also works on Brazil Foreign Corrupt Practice Act Violation Whistleblower Reward Lawsuits, Russian International Bribery Scheme Whistleblower Reward Lawsuits, Government Contractor Fraud Whistleblower Lawsuits, Medicare Illegal Kickback Lawsuits, Confidential Financial Analyst Whistleblower Reward Lawsuits, Mexico Illegal Kickback Whistleblower Reward Lawsuits, and other whistleblower recovery lawsuits.
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If you are the original source with special knowledge of of international bribery schemes, illegal kickbacks, or other illicit payments regarding Chinese international trade, please feel free to contact Chinese Port Official Bribe Whistleblower Lawyer, China Customs Agent Bribe Lawyer, and Chinese International Business Illegal Bribe Whistleblower Reward Lawyer Jason Coomer via e-mail message or use our submission form to have a foreign corrupt practices act attorney review a potential Chinese Port Official Bribe Whistleblower Lawsuit, Chinese Import Bribe Whistleblower Reward Lawsuit, Foreign Corrupt Practices Act Violation Whistleblower Reward Lawsuit, or other Foreign Corruption Practices Act Securities and Exchange Commission Bounty Action.
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