According to the declaration, these factors included:

“Liberty Mutual’s timely and voluntary self-disclosure of the misconduct to the Fraud Section in March 2024, which was identified during an internal investigation that was still ongoing at the time of the disclosure;
Liberty Mutual’s full and proactive cooperation in this matter (including its provision of all known relevant facts regarding the misconduct, including information regarding the individuals involved) and its agreement to continue to cooperate with any ongoing Government investigations and any prosecutions that have resulted or might result in the future;
the nature and seriousness of the offense;
Liberty Mutual’s timely and appropriate remediation, including the company’s early and fulsome acceptance of responsibility, its thorough and systematic root-cause analysis and the company’s separation from personnel involved in the misconduct;
Liberty Mutual’s significant improvements to its compliance program and internal controls, including enhanced vetting, monitoring, and oversight of payments to third parties throughout its global markets, structural reorganization coupled with increased legal and compliance resources, and the implementation of enhanced compliance policies, including with respect to use of social media and ephemeral messaging applications for business purposes;
the absence of aggravating circumstances; and
the fact that Liberty Mutual agrees to disgorge the amount of its ill-gotten gains.”

Pursuant to the DOJ’s letter, Liberty Mutual has agreed to disgorge just under $4.7 million, which is representative of the profits the insurer gained from its relationship with the bribed banks.

Special Reports /

Liberty Mutual to pay $4.7M in bribery settlement

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