Engineering / Construction

Corporate Headquarters

Munich, Bavaria, Germany

Summary of Allegations:

Nationality of Foreign Officials: Georgia

Summary of Allegations:

Linde North America Inc. and Linde Gas North America LLC acquired Spectra Gases, Inc. in October 2006. On 13 November 2006, Spectra Gases purchased a boron column and other assets and equipment from the National High Technology Center, an entity owned and controlled by the Republic of Georgia. The boron column was to be used to produce boron gas, and executives of Spectra Gases agreed to share profits earned from the sale of the boron gas with officials at the National High Technology Center. This agreement was made in return for the officials' assistance in making sure that Spectra Gases was the purchaser of the boron column.

Spectra Gases used a management agreement with a company owned by the officials to move 75% of the profits from the boron gas sales to the officials.

Approximate Alleged Payments to Foreign Officials: 75% of profits from the sale of boron gas

Business Advantage Allegedly Obtained: The purchase of a boron column to produce boron gas

Nationality of Foreign Officials: Iraq

Summary of Allegations:

On 29 December 2006, the Washington Post reported the announcement by prosecutors in Munich that they had initiated an investigation of allegations that Linde had paid bribes in Iraq as part of the United Nations' Oil-for-Food Program. According to the Financial Times' report on 30 December 2006, the Independent Inquiry Committee (which investigated the corruption allegations regarding the Oil-for-Food Program) published documents alleging that Linde had paid "$32,364 in 'after-sales-service fees' to Iraq in return for a contract for an air separation plant and parts worth $356,038." The Financial Times reported that prosecutors in Munich had raided Linde's offices in November 2006 as part of their investigation of Linde.

On 8 June 2011, the Wall Street Journal reported that Linde had settled allegations of bribery with the state of Bavaria for EUR 35 million. A company spokesman said that the settlement "was compensation for economic advantages gained through the unlawful conduct of outside parties."

Approximate Alleged Payments to Foreign Officials: USD 32,364

Business Advantage Allegedly Obtained: Contract for plant and parts worth USD 356,038

Enforcement Results

Agencies: Germany: Munich Public Prosecutor's Office

Results: Restitution

Year Resolved: 2011

Compliance Monitor:

Ongoing: No


The Wall Street Journal reported on 8 June 2011 that Linde settled allegations of bribery by paying EUR 35 million to the state of Bavaria. According to a Linde spokesman, "no unlawful behavior at Linde was established. The payment, he said, was compensation for economic advantages gained through the unlawful conduct of outside parties."

Agencies: United States: Department of Justice

Results: Disgorgement, No Action

Year Resolved: 2017

Compliance Monitor:

Ongoing: No


The U.S. Department of Justice closed its investigation of Linde North America Inc and Linde Gas North America LLC on 16 June 2017. The companies agreed to disgorge USD 7,820,000 in profit or benefits received from the alleged misconduct and forfeit USD 3,415,000 in corrupt proceeds.

  • Linde AG ("Linde")
  • Linde North America Inc.
  • Linde Gas North America LLC
Key Takeaways

Companies can be liable for the corrupt payments that third parties make on their behalf.

Countries other than the United States are enforcing laws prohibiting the payment of bribes to foreign government officials.

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