On June 16, Florida government contracting and defense company IAP Worldwide Services Inc. (“IAP”) entered into a non-prosecution agreement (“NPA”) and agreed to pay a $7.1 million penalty to resolve a government investigation into whether IAP conspired to bribe Kuwaiti officials to secure a government contract.  Michael Rama, former vice president of IAP, also pled guilty to conspiracy to violate the anti-bribery provisions of the FCPA.  In 2004, Kuwait’s Ministry of the Interior initiated the Kuwait Security Program (“KSP”) to provide nationwide surveillance capabilities for Kuwaiti government agencies. The Ministry of the Interior was responsible for selecting contractors to facilitate and implement the project.  According to court papers, IAP and Rama schemed to ensure that IAP could tailor the requirements for the KSP contracts so that the company would have an advantage in the bidding.  Executives and senior employees of IAP, including Rama, set up a shell company called “Ramaco” to conceal IAP’s role in crafting the requirements.  Ramaco secured one contract for the KSP for approximately $4 million; Rama and IAP then agreed that half of that amount would be used bribe Kuwaiti government officials to assist IAP in obtaining a second, more lucrative contract.  IAP and its co-conspirators also paid a consultant approximately $1,783,688 to bribe Kuwaiti government officials.  DOJ cited IAP’s cooperation among “a variety of factors” as the basis for the NPA.  The NPA requires IAP to: (1) review its existing internal controls, policies and procedures; (2) make modifications to ensure that the company maintains accurate record keeping and a rigorous anti-corruption compliance program; (3) report periodically to DOJ regarding remediation and implementation of the compliance program and internal controls, policies and procedures review; and (4) continue its cooperation with DOJ.  (E.D. Va.).  DOJ Press Release