Flavio Ricotti, a former executive with Control Components, Inc. (“CCI”), has reached a settlement with the DOJ over charges for conspiring to violate the FCPA and the Travel Act.


  • In 2009, CCI, a California-based valve company, pled guilty to a three-count criminal information that charged two counts of violating the antibribery provisions of the FCPA and one count of conspiracy to violate the FCPA and Travel Act.
  • CCI violated the FCPA by making corrupt payments totaling approximately US$4.9 million to officers and employees of state-owned enterprises (SOEs) – “foreign officials” under the FCPA – for the purpose of obtaining or retaining business. CCI generated approximately US$31.7 million in net profits as a result of these corrupt payments.
  • In connection with the 2009 proceeding, Ricotti has pled guilty to one count of conspiring to violate the FCPA and the Travel Act.
  • From 2001 to 2007, Ricotti served as CCI’s Director and then Vice President of Sales for Europe, Africa, and the Middle East. Ricotti admitted that, in 2002, he authorized a decision to offer a 1.2% commission to an employee of a private Qatari company on whose contract CCI was bidding, in exchange for the employee’s agreement to share confidential information on CCI’s competitors and exercise influence in CCI’s favor. In 2003, Ricotti conspired with another CCI employee to bribe an official of Saudi Aramco, a Saudi oil company, in the amount of approximately $43,000 to secure a valve contract for CCI.


  • Ricotti faces a maximum five-year prison sentence, $250,000 fine,and three years of supervised release.


  • Payments were made to foreign officials in several countries, including Qatar and Saudi Arabia.
  • Some payments were made to individuals who had the power to award contracts or influence projects’ technical specifications so as to favor CCI.
  • In addition to violating the the FCPA, Ricotti admitted that his conduct violated the Travel Act, 18 USC 1952. The Travel Act makes it unlawful to travel in interstate or foreign commerce, or use any facility of interstate or foreign commerce, with the intent to promote, manage, establish, carry on, or facilitate the promotion, management, establishment or carrying-on of any unlawful activity.