Business Crimes Hotline

FCPA Sting Case Witness Sentenced

On July 31, 2012, the government's cooperating witness in its widely publicized Foreign Corrupt Practices Act (FCPA) sting was sentenced to 18 months in prison by U.S. District Judge Richard Leon in Washington, DC. (See details of the trial in the lead article in this issue.) Richard Bistrong, a former vice president for international sales at Armor Holdings (which was bought by BAE Systems PLC), had previously admitted to conspiring to bribe government officials to gain contracts for Armor Holdings, after the company initiated a voluntary disclosure of its activities to the government. Bistrong pled guilty to a single count of conspiracy to violate the FCPA in February 2009. After speaking with government prosecutors, Bistrong agreed to go undercover for nearly three years to, among other things, help the government build a case against military and police-equipment industry employees, as part of a sting operation where a federal agent posed as a representative of the West African nation of Gabon. Bistrong's “extraordinary cooperation” led to the government indicting 22 individuals in 2009; however, after three acquittals and two mistrials, the government dropped the charges against the remaining individuals earlier this year.