Mercernaries

Top executives at Blackwater Worldwide authorized secret payments of about $1 million to Iraqi officials that were intended to silence their criticism and buy their support after a September 2007 episode in which Blackwater security guards fatally shot 17 Iraqi civilians in Baghdad, according to former company officials.

Blackwater approved the cash payments in December 2007, the officials said, as protests over the deadly shootings in Nisour Square stoked long-simmering anger inside Iraq about reckless practices by the security company’s employees. American and Iraqi investigators had already concluded that the shootings were unjustified, top Iraqi officials were calling for Blackwater’s ouster from the country, and company officials feared that Blackwater might be refused an operating license
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The Nisour Square shooting was the bloodiest and most controversial episode involving Blackwater in the Iraq war. At midday on Sept. 16, 2007, a Blackwater convoy opened fire on Iraqi civilians in the crowded intersection, spraying automatic weapons fire in ways that investigators later claimed was indiscriminate, and even launching grenades into a nearby school. Seventeen Iraqis were killed and dozens more were wounded.

The matter set off an international outcry and intense debates in Iraq and the United States over the role of private contractors in war zones. Many Iraqis condemned Blackwater, which they had long seen as an arrogant rogue operation, and Prime Minister Nuri Kamal al-Maliki declared that the Blackwater shooting was a challenge to his nation’s sovereignty

Blackwater Said to Approve Iraqi Payoffs After Shootings
Mazzetti and Risen
New York Times, November 11, 2009

U.S. firms seeking to do business in foreign markets must be familiar with the FCPA. In general, the FCPA prohibits corrupt payments to foreign officials for the purpose of obtaining or keeping business. In addition, other statutes such as the mail and wire fraud statutes, 18 U.S.C. § 1341, 1343, and the Travel Act, 18 U.S.C. § 1952, which provides for federal prosecution of violations of state commercial bribery statutes, may also apply to such conduct.

The Department of Justice is the chief enforcement agency, with a coordinate role played by the Securities and Exchange Commission (SEC).

US foreign Corrupt Practices Act