United States v. Napco Int’l, Inc. and Venturian Corp. (D. Minn. 1989)
United States v. Richard H. Liebo (D. Minn. 1989)

• Case Name
• United States v. Napco Int’l, Inc. and Venturian Corp. (D. Minn. 1989)
  United States v. Richard H. Liebo (D. Minn. 1989)

• Date Filed
• 04/20/1989

• Enforcement Agency
• DOJ

• Countries
• Niger

• Foreign Official
• Two officials of the Niger government, the First Counselor of the Embassy in Washington, D.C. and the Chief of Supply for the Niger Air Force.

• Date of Conduct
• 1983 to 1987

• Nature of Business
• Sale of military equipment and supplies by Venturian Corp. (“Venturian”), a Minnesota corporation and an issuer, and by its wholly-owned subsidiary, Napco Int’l, Inc. (“Napco”), a Minnesota corporation and a domestic concern.  Richard Liebo was the vice president of the Aerospace Division of Napco.

• Influence to be Obtained
• To obtain certain Foreign Military Service contracts for spare parts and maintenance for C-130 military aircraft from the Niger Ministry of Defense.

• Enforcement
• Napco and Venturian pleaded guilty to a three-count information, including one count charging bribery of a foreign official, and were fined $785,000 in the aggregate.   Liebo was convicted of an FCPA bribery violation and of false statements and sentenced to 18 months’ incarceration, suspended with three years’ probation, which included 60 days of home confinement and 600 hours of community service.

• Amount of the Value
• $130,813.83, equaling 10% of the net revenues on contracts.

• Amount of Business Related to Payment
• $3.2 million in contracts.

• Intermediary
• Two relatives of the Chief of Supply for the Niger Air Force, falsely posing as agents of Napco in Niger, were used to conceal the bribes.

• Total Sanction
• $ 785,000

• Compliance Monitor
• No

• Reporting Requirements
• No

• Case is Pending?
• No

Napco Int’l, Inc. 

• Citation
• United States v. NAPCO Int’l, Inc., No. 4-89-65 (D. Minn. 1989); 

• Date Filed
• 04/20/1989

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Aiding and Abetting: Anti-Bribery
  • Books-and-Records
  • Conspiracy: Anti-Bribery
  • Conspiracy: Books-and-Records
  • Conspiracy: Internal Controls

• Other Statutory Provision
• False Statements.

• Disposition
• Plea Agreement

• Defendant Jurisdictional Basis
• Domestic Concern, Conspiracy

• Defendant's Citizenship
• United States

• Individual Sanction
• $785,000.

Venturian Corp.

• Citation
• United States v. NAPCO Int’l, Inc., No. 4-89-65 (D. Minn. 1989);

• Date Filed
• 04/20/1989

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Aiding and Abetting: Anti-Bribery
  • Books-and-Records
  • Conspiracy: Anti-Bribery
  • Conspiracy: Books-and-Records
  • Conspiracy: Internal Controls

• Other Statutory Provision
• False Statements.

• Disposition
• Plea Agreement

• Defendant Jurisdictional Basis
• Issuer, Conspiracy

• Defendant's Citizenship
• United States

• Individual Sanction
• $0

Richard H. Liebo

• Citation
• United States v. Liebo, No. 4-89-76 (D. Minn. 1989).

• Date Filed
• 04/20/1989

• Filed Under Seal
• No

• FCPA Statutory Provision
• • Aiding and Abetting: Anti-Bribery
  • Aiding and Abetting: Books-and-Records
  • Anti-Bribery
  • Books-and-Records
  • Conspiracy: Anti-Bribery
  • Conspiracy: Books-and-Records
  • Conspiracy: Internal Controls

• Other Statutory Provision
• False Statements; Aiding and Abetting (False Statements).

• Disposition
• Convicted

• Defendant Jurisdictional Basis
• Conspiracy, Aiding and Abetting, Agent of Issuer, Agent of Domestic Concern

• Individual Sanction
• 18-Months Imprisonment.