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U.S. v. Salam

 
:
Salam, Faheem Mousa
:
DOJ Criminal
:
March 8, 2006
:
U.S. v. Salam
:
U.S. v. Salam, No. 06-0157 (D.D.C. 2007)
:
Salam was prosecuted under the alternative jurisdiction provision set forth in 15 U.S.C. 78dd-2(i), which prohibits corrupt acts by U.S. persons outside the United States. Salam is a naturalized U.S. citizen, and thus a U.S. person for purposes of that provision.
:
Aerospace/Defense
:
Iraq
:
2005; 2006
:
An Iraqi police official and an agent for the office of the Special Investigator General for Iraq Reconstruction.
:
Faheem Mousa Salam violated the FCPA by offering $60,000 to an Iraqi police official and between $28,000 and $35,000 to an agent for the Special Investigator General for Iraq Reconstruction ("SIGIR"). Salam offered these bribes in exchange for the the Civilian Police Assistance Training Team's ("CPATT") purchase of armored vests and a large map printer for $1,000,000. CPATT makes all purchases of equipment for the Iraqi Police, Iraqi Border Guard, and Iraqi Special Police force (together the "Iraqi Police Force").

Salam worked as a government contractor performing translation services for Titan Corporation ("Titan") in Iraq. On December 12, 2005, a high-ranking Iraqi Ministry of Interior official introduced Salam to a Senior Iraqi official with the Iraqi Police Force. Salam offered the official $60,000 in exchange for CPATT's purchase of a large-scale map printer for $90,000 and 1,000 armored vests for $1,000 apiece. Salam followed up with the official on January 2, 2006 lowering the bribe to $50,000 and the price of the vests to $800 a piece.

The official contacted SIGIR, which monitored the next conversation between Salam and the official. Salam again offered to reduce the price of the vests and the bribe. A SIGIR agent posing as an officer of CPATT began negotiating the transaction with Salam via email. The agent and Salam met in person on February 6, 2006 and finalized a price of $92,000 for the printer and $600 for each vest. Salam offered to wire the agent $28,000-$35,000 to process the contract, depending on the final purchase price. Two days later, the agent emailed Salam to thank him for the meeting and Salam responded by asking the agent to expedite the process. After a second meeting, where Salam indicated that he could give the agent $100 up front upon completion of the paperwork, Salam backed out of the transaction. The transaction was never consummated.
:
Anti-bribery (Domestic Concern)
:
Fine, Imprisonment, Plea
:
The court imposed a special assessment against Salam of $100.
:
100
:
36
:
Additionally, Salam was sentenced to 24 months of supervised release and 250 hours of community service.

The DOJ assigned Salam a base offense level of 12, added two levels for offering multiple bribes, six levels for offering a bribe of greater than $30,000, and 4 levels for offering a bribe to a high-level decision-maker. The DOJ then subtracted 3 levels based on Salam's "acceptance of responsibility" to arrive at a final adjusted offense level of 21.
:
Domestic Concern
:
U.S.
:
Contract Procurement/Retention
:
1,090,000
:
Cash, Wire/check
:
Direct
:
60,000
:
Iraq
:
No
:
No