US justice department exempts Indian bribery case

Mashrukh Khan: Liberty Mutual Insurance Company received a declination from the U.S. Department of Justice on August 7, 2025, avoiding prosecution for Foreign Corrupt Practices Act violations despite evidence of bribery by its Indian subsidiary.

From 2017 to 2022, employees of Liberty General Insurance in India paid approximately $1.47 million in bribes to officials at six state-owned banks. The payments, often disguised as marketing expenses and routed through third-party intermediaries, secured customer referrals to the subsidiary’s insurance products. The scheme generated about $9.2 million in revenue and $4.7 million in profits for Liberty Mutual.

The DOJ declined charges citing the company’s timely voluntary self-disclosure in March 2024 during an internal investigation, full cooperation including details on involved individuals, separation of responsible personnel, acceptance of responsibility, and significant enhancements to its global compliance program and internal controls. Liberty Mutual agreed to reimburse $4,699,088, representing the ill-gotten profits.

This resolution marked the first public corporate FCPA declination under the current administration following a review of enforcement policies. No individuals were charged in the public announcement, and the matter highlighted the benefits of proactive remediation in international insurance operations.