HMT LLC, a liquid storage tank company based in The Woodlands bribed Venezuelan and Chinese officials. A Chinese subsidiary of NCH Corp., an industrial supply and maintenance company based in Irving illegally provided Chinese officials with cash, gifts, meals and entertainment.
Both companies could have faced a hefty fine or even a criminal indictment. But instead they agreed with the U.S. Department of Justice to a relative slap on the wrist: The disgorgement of their illegally gained profits—in NCH’s case, an amount totaling just $335,342—in exchange for a declination of prosecution. They owe their good fortune to the DOJ’s new one-year pilot enforcement program, announced in April, which encourages companies to self-report illegal payments under the Foreign Corrupt Practices Act.
