AAR Settlement: Cooperation, Remediation and No Monitor

In December 2024, AAR Corp. (AAR), a publicly traded aviation services company, entered into probably the last FCPA settlement for some time, considering the recent executive order pausing FCPA enforcement. The company's cooperation and remediation efforts enabled it to avoid the imposition of an independent compliance monitor while settling allegations that it engaged in bribery in South Africa and Nepal. This second article in a two-part series discusses AAR’s those cooperation and remediation measures, and looks at risks in the aviation sector. The first article laid out facts underlying the bribery schemes and examined how the company was able to receive self-reporting credit even though the DOJ already knew about the misconduct, earning it a non-prosecution agreement rather than the more common deferred prosecution agreement. See “Executive Order Presses Pause on FCPA Enforcement” (Feb. 12, 2025).

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