DOJ Declines Prosecution of Liberty Mutual for FCPA Violations: Key Compliance Lessons for Financial Institutions

The U.S. Department of Justice (DOJ) Criminal Division’s Fraud Section issued a declination letter regarding its investigation of Liberty Mutual Insurance Company for alleged violations of the Foreign Corrupt Practices Act (FCPA) on Aug.7, 2025. Despite evidence of bribery by Liberty Mutual’s Indian subsidiary, the DOJ declined to prosecute — underscoring the value of proactive compliance, robust internal controls and prompt remediation for organizations operating in high-risk jurisdictions.