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Deferred Prosecution Agreement Statistics

[99] See z.B. Apotex DPA, note 14 above, under heading 10 (“If, during the term of this Agreement, the United States finds in its own discretion that Apotex . Does not cooperate. Apotex will be continued thereafter. BHBM Tax DPA, a.o.o. 65, à 6 (“If during the term of the agreement. the bank does not cooperate, as provided for in the agreement. the bank and hapoalim (Latin America) S.A. will then be prosecuted. »). As part of the deal, Engevix will pay the value of the alleged bribes, which amounted to 315.84 million reais (about $78 million); 105 million reais (approximately $26 million) in de-mination; and 95.44 million reais (approximately $23 million) in administrative and civil penalties. [384] Payments are made in instalments until 2046. [385] The agreement also requires Engevix to improve its compliance program by preventing inappropriate behavior and promoting ethics and transparency throughout the company. [386] [6] What is striking is that this year, none of the 17 companies that resolved DOJ investigations with NPLs and DPAs voluntarily disclosed the alleged misconduct, and only two companies — both runaway in unusual extenuating circumstances — received NPAs. The extreme measure of effectively exiting the activity may have weighed in favour of an unusual indulgence in the context of this year`s agreements.

June 25, 2019, Merrill Lynch Commodities, Inc. . . .