On January 13, 2017, Sociedad Quimica y Minera de Chile (SQM) entered into a DPA and agreed to pay more than $15 million as a criminal penalty for failure to implement internal controls and falsifying its books and records under the FCPA.  The DPA provides that between 2008 and 2015, SQM made donations to foundations tied to Chilean politicians, including approximately $630,000 to foundations controlled by a Chilean official with influence over the Chilean government’s mining plans.  Additionally, payments to vendors associated with politicians were inaccurately listed in SQM’s books and records as consulting and professional services payments when no services were received by SQM.  SQM admitted to failing to implement internal controls sufficient to ensure that these payments complied with Chilean law and to falsifying its books and records to conceal these payments.  In addition to the penalty, SQM has agreed to continue to cooperate with the investigation, enhance its compliance program, implement rigorous internal controls and retain an independent compliance monitor for two years, with a self-reporting obligation to continue for a third year.  The Department stated that the terms of of DPA included a 25% reduction of the low end of the U.S. Sentencing Guidance, based in part on the fact that SQM did not voluntarily disclose the FCPA violation but did cooperate with the investigation and substantially remediate. DOJ Press Release