| Agreement Information |
| Type of crime: |
Other |
| Docket text*: |
|
| Agreement text: |
PDF
|
| Disposition type: |
DP
|
| Agreement date (yyyy-mm-dd): |
2007-01-18 |
| Jurisdiction: |
Massachusetts
|
| Document source: |
None |
| Fines / Punishment |
| Length of agreement (in months): |
27 |
| Fine amount ($): |
2,121,688 |
| Restitution amount ($): |
194,578 |
| Forfeiture/disgorgement amount ($): |
0 |
| Additional regulatory fine amount ($): |
194,578 |
| Community service / other penalties ($): |
| Total payments ($): |
2,316,266 |
| Related Cases |
| Parallel regulatory action? |
-
|
| Regulatory fine ($): |
-
|
| Regulatory disgorgement/forfeiture ($): |
-
|
| Total regulatory payment amount ($): |
-
|
| Payments description: |
-
|
| Parallel civil suit? |
-
|
| Civil judgment? |
-
|
| Civil judgment amount: |
-
|
| Monitor |
| Independent monitor required? |
-
|
| Other officer required? |
Yes
|
| Compliance program required? |
Yes
|
| New position required? |
-
|
| Outside experts required? |
Yes
|
| Governance changes required? |
Yes
: Will maintain and staff an internal auditing program that encompasses international operations, and the staff will report on the results of these internal audit tests in writing to the Audit Committee of the Board of Directors on an annual basis; the most senior site finance and accounting manager at each international site will be supervised by both the Chief of Party or Project Director in the country and a US based accounting manager (each yeat an auditor will meet with each of these managers to review their compliance with company policy; the results of these reviews will be compiled in an annual written report signed by the Director of Internal Audit and submitted to the Audit Committee of the Board of Directors)
|
| Who selects monitor? |
-
|
| Length of monitorship (in months): |
-
|
| Monitor name: |
-
|
| Was the monitor a former prosecutor? |
-
|
| Other Agreement Variables |
| Leniency considerations? |
Yes
: Outside auditor.
|
| Accept responsibility? |
Yes
|
| Statement of facts: |
Yes
|
| United States Sentencing Guidelines? |
Yes
: Internal auditing program
|
| Description of pre-agreement compliance |
Yes
: Abt "has established" a Foreign Currency Transaction Policy and Procedure
|
| Regulatory compliance required? |
-
|
| Unrelated terms: |
-
|
| Privacy waiver? |
-
|
| Fine calculation included? |
-
|
| Fine description: |
$2.9 million in fines and restitution
|
| Can DOJ unilaterally terminate agreement? |
Yes
|
| Regulatory agency: |
U.S. Agency for International Development (USAID)
|
| Part of Swiss Bank Program? |
-
|
| Notes: |
Second time that ABT Assoc. came to an agreement with U.S. Attorney Office of Mass. For over-billing. In 1999, paid $1.9 million for premature billing of subcontractor costs.
|
*The docket above is unofficial and may be incomplete or out-of-date. The official docket is available on
PACER (fees may apply).