A report on Monday, October 3 from Bloomberg Markets Magazine detailed a years-long scheme by Koch Industries, Inc. to make improper payments to win contracts in six countries – payments which the company admitted "constitute violations of criminal law." The article states that the Justice Department would not confirm or deny the existence of any investigation into the activities, but such an investigation seems likely given the articles description of events that may violate the FCPA or the laws regarding the Iran Trade Embargo.

The article cites the 2008 investigation of then-Compliance Officer and Ethics Manager Ludmilla Egorova-Farines as triggering further investigations by the company discovering a pattern of payments tracing back to 2002. According to a letter from Koch Industries, Inc. which became public in a civil court case in France, "[t]hese activities constitute[d] violations of criminal law."

It remains to be seen U.S. regulators will do with Koch Industries. The Department of Justice, which would not commit on the matter, has not limited its charges to FCPA violations in other cases, and has have used other legal theories, such as money laundering (against individuals involved in the Haitian telecommunications industry, as discussed here) and violations of the Travel Act.

The article referred to other legal actions brought against the company prior to 2002 and cited testimony from an employee who said "he and his colleagues were shown by their managers how to steal and cheat – using techniques they called the Koch method." The article also emphasized the political leanings of the Charles and David Koch (the latter of whom ran as a vice-presidential candidate on the Libertarian ticket in 1980 and advocated abolishing the Federal Reserve System and the FBI).

Because it is privately held, the shares of Koch Industries are not traded on Wall Street. The "Occupy Wall Street" movement (whose protests resulted in 700 arrests at the Brooklyn Bridge on Saturday and are supposed to extend to Washington, DC on Thursday, according to the Washington Post) may have a new target. As the Washington Post article stated: "[t]he primary theme [of the protests] is that corporate capitalists, backed by corrupt politicians, have tipped the balance of the economic system too far in favor of the powerful, thus condemning the regular guy to a sea of debt and little opportunity." According to the Huffington Post, protests have been planned for the Koch Industries headquarters by the "Occupy DC" movement this week.