United States v. SSI Int’l Far East, Ltd. (D. Or. 2006)
In re Schnitzer Steel Industries, Inc. (2006)

• Case Name
• United States v. SSI Int’l Far East, Ltd. (D. Or. 2006)
  In re Schnitzer Steel Industries, Inc. (2006)

• Date Filed
• 10/10/2006

• Enforcement Agency
• DOJ

• Countries
• China, Korea, South

• Foreign Official
• Managers of Government Customers.

• Date of Conduct
• 1995 to 2004

• Nature of Business
• Sale of scrap metal by SSI International Far East, Ltd. (“SSI Korea”), a wholly-owned South Korean subsidiary of Schnitzer Steel Industries, Inc. (“Schnitzer Steel”), a U.S. corporation.

• Influence to be Obtained
• Sale of scrap metal by SSI International Far East, Ltd. (“SSI Korea”), a wholly-owned South Korean subsidiary of Schnitzer Steel Industries, Inc. (“Schnitzer Steel”), a U.S. corporation.

• Enforcement
• SSI Korea agreed to plead guilty to violating the anti-bribery and accounting provisions of the FCPA and pay a $7.5 million penalty.  Schnitzer Steel entered into a three-year deferred prosecution agreement and agreed to retain a compliance monitor for three years.  In the SEC proceeding, Schnitzer Steel has agreed to pay disgorgement and prejudgment interest of $7.7 million and retain a compliance monitor.

• Amount of the Value
• $204, 537 (foreign officials) and $1,683,672 (private parties).

• Amount of Business Related to Payment
• Gross Revenue of $96,455,350 and Profits of $6,279,095 from Government Entities and Gross Revenue of $603,593,957 and Profits of $55,327,840 from Private Entities.

• Intermediary
• None

• Total Sanction
• $ 7,500,000

• Compliance Monitor
• Yes

• Reporting Requirements
• No

• Case is Pending?
• No

• Total Combined Monetary Sanction
• $ 15,225,201

• Related Enforcement Actions
• In the Matter of Schnitzer Steel Industries, Inc. (2006) 
  SEC v. Robert W. Philip (D. Or. 2008)
  In the Matter of Schnitzer Steel Industries, Inc. (2006) 
  SEC v. Si Chan Wooh (D. Or. 2007)
  United States v. Si Chan Wooh (D. Or. 2007)
  

SSI Int’l Far East, Ltd. 

• Citation
• United States v. SSI Int’l Far East, Ltd., No.3: 06-cr-00398 (D. Or. 2006); In re Schnitzer Steel Industries, Inc. (2006).

• Date Filed
• 10/10/2006

• Filed Under Seal
• No

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

• Other Statutory Provision
• Wire Fraud

• Disposition
• Plea Agreement

• Defendant Jurisdictional Basis
• Territorial Jurisdiction

• Defendant's Citizenship
• United States

Schnitzer Steel Industries, Inc. 

• Citation
• In re Schnitzer Steel Industries, Inc. (2006).

• Date Filed
• 10/10/2006

• Filed Under Seal
• No

• FCPA Statutory Provision

• Disposition
• Plea Agreement

• Defendant Jurisdictional Basis
• Issuer

• Defendant's Citizenship
• Korea, South