Suppose A is ordered to pay B $160. However, A claims an inability to pay that amount and based on this inability to pay B agrees to accept only $25. The following year, a year during which A publicly discloses evidence of financial health, A pays C $45. You might conclude that B was duped.Convert the above numbers to millions, insert Innospec for A, insert the DOJ and SEC for B, and insert NewMarket (a competitor corporation) for C, and you now have a real scenario.
Read more: Innospec – Were The DOJ and SEC Duped? — FCPA Professor