Between March 9, 2004, and May 1, 2011 (the relevant period), certain former senior executives of the Contracting Party, who are no longer employees, solicited some of the employees of the Contracting Party, including certain members of the Office of the President, to make political contributions at the federal level. In some cases, these contributions were reimbursed by the Contracting Party in the form of false refunds for personal expenses or payment of fictitious bonuses or other benefits which, according to information obtained in the context of the Commissioner's investigation, were for a total value of $117, 803.49.
During the relevant period, and as they had previously offered to do, the Contracting Party reimbursed federal political contributions made by its employees and, in some cases, by the spouses of its employees.