Our Website Uses Cookies 


We and the third parties that provide content, functionality, or business services on our website may use cookies to collect information about your browsing activities in order to provide you with more relevant content and promotional materials, on and off the website, and help us understand your interests and improve the website.


For more information, please contact us or consult our Privacy Notice.

Your binder contains too many pages, the maximum is 40.

We are unable to add this page to your binder, please try again later.

This page has been added to your binder.

NCH and HMT Avoid FCPA Prosecution for China Issues

October 7, 2016, Covington Alert

On September 29, 2016, the U.S. Department of Justice (“DOJ”) issued letters of declination to NCH Corporation (“NCH”) and HMT LLC (“HMT”). Both companies are Texas-based “domestic concerns.” The letter to NCH, an industrial supply and maintenance company, relates to an investigation into possible violations of the anti-bribery provisions of the U.S. Foreign Corrupt Practices Act (“FCPA”) based on alleged bribes paid by its Chinese subsidiary to Chinese state-owned customers. The letter to HMT, a company that manufactures, supplies, and services aboveground liquid storage tanks for oil and gas companies, relates to an investigation into possible violations of the anti-bribery provisions of the FCPA based on alleged bribes paid by an HMT sales agent in Venezuela to Petroleos de Venezuela S.A. (“PDVSA”) and bribes paid by an HMT distributor in China to state-owned customers.

Share this article: