OO violations,” three former Haitian officials involved in the sale of defense articles and services valued at $500,000 or same scheme were convicted of money laundering," more triggers disclosure requirements concerning fees and commissions, including bribes, in an aggregate amount of Mail and Wire Fraud $100,000 or more.” Violations of AECA and ITAR can The mail and wire fraud statutes may also apply. In result in civil and criminal penalties.”° 2006, for example, a wholly owned foreign subsidiary of a US. issuer pleaded guilty to both FCPA and wire fraud Tax Violations counts where the scheme included overbilling the sub- Individuals and companies who violate the FCPA may sidiary’s customers—both government and private—and also violate U.S. tax law, which explicitly prohibits tax deduc- using part of the overcharged money to pay kickbacks to the tions for bribes, such as false sales “commissions” deductions customers’ employees. The wire fraud charges alleged that intended to conceal corrupt payments.’ Internal Revenue the subsidiary had funds wired from its parent’s Oregon Service-Criminal Investigation has been involved in a num- bank account to off-the-books bank accounts in South ber of FCPA investigations involving tax violations, as well as Korea that were controlled by the subsidiary. The funds, other financial crimes like money laundering. amounting to almost $2 million, were then paid to manag- ers of state-owned and private steel production companies in China and South Korea as illegal commission payments and kickbacks that were disguised as refunds, commissions, and other seemingly legitimate expenses.” Certification and Reporting Violations Certain other licensing, certification, and reporting requirements imposed by the U.S. government can also be implicated in the foreign bribery context. For example, as a condition of its facilitation of direct loans and loan guar- antees to a foreign purchaser of US. goods and services, the Export-Import Bank