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First Criminal Prosecution for Spoofing: High Frequency Trading Firm Owner Indicted in Northern District of Illinois

On October 2, 2014, the U.S. Attorney for the Northern District of Illinois announced the indictment of Michael Coscia, the owner of Panther Energy Trading (“Panther”), for six counts of commodities fraud and six counts of...more

UK Government Proposes New Insider Dealing Powers in the Wholesale Energy Markets

The Department of Energy and Climate Change published a Consultation on 6 August 2014 seeking views on its proposals to introduce new criminal offences for insider dealing in and the manipulation of the wholesale energy...more

Red Notice Newsletter - August 2014

Welcome to the August 2014 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, the former CEO of an aviation company pleads guilty to participating in an...more

Former Maxwell Technologies Executive Indicted On FCPA Charges

On October 15, the DOJ filed an indictment against a Swiss national and former executive at Maxwell Technologies—a U.S.-based energy storage and power-delivery company—for alleged violations of the FCPA. The DOJ claims that...more

UK Bribery Act: Serious Fraud Office Announces its First Prosecutions

On 14 August, the Serious Fraud Office (SFO) announced that four men connected to Sustainable AgroEnergy plc have been charged with offences of conspiracy to commit fraud by false representation and conspiracy to furnish...more

Federal Authorities Announce Major FCPA Settlement

On May 29, the DOJ and the SEC announced that a French oil and gas company will pay nearly $400 million to resolve allegations that the company made illegal payments through third parties to an Iranian official in exchange...more

We Say Good-Bye To The Secretary Of Defense And Total Says Hello To Two Monitorships – Total Part III

Today I finalize my review of the Total SA (Total) Foreign Corrupt Practices Act (FCPA) enforcement action....more

Return To The Baker’s Dozen In A Best Practices Compliance Program – Total Part II

Yesterday I reviewed the facts surround Total SA’s (Total) lengthy bribery scheme to win contracts in Iran....more

Total Settles FCPA Bribery Claims for $398M

On May 29, French oil and gas company, Total SA, agreed to pay $398 million to settle US civil and criminal allegations that it paid bribes to win oil and gas contracts in Iran in violation of the Foreign Corrupt Practices...more

Total S.A. to Pay $398.2M to Settle Alleged FCPA Violations

On May 29, 2013, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) announced agreements with Total S.A. (Total) to settle alleged Foreign Corrupt Practices Act (FCPA or the Act) violations for a...more

Total Switches To Settle Rather Than Fight

For anyone who grew up in the 1960s, I am sure that you remember the touchstone slogan for Tareyton cigarettes, “I’d rather fight than switch”. ...more

Corruption in The Energy Sector: Criminal Fines, Civil Judgments, And Lost Arbitrations

Synopsis - This article examines the anti-bribery legislation of three countries, the United States, Canada, and the United Kingdom. The legislation of the three countries is compared and virtually all the criminal...more

Anti-Corruption Law And The Oil And Gas Industry: Evolutions In Both Demand Vigilance

Businesses in the oil and gas industry are cautioned to pay careful attention to evolutions in anti-corruption law in the jurisdictions where they operate. The U.S. government has successfully enforced the Foreign Corrupt...more

How to Conduct Routine Internal Investigations [Video]

The art of day-to-day internal investigations has been ignored in favor of media reports on high-profile, high-stakes internal investigations. With the increasing threat of whistleblower complaints and increasing...more

Doing Business In Italy - Step Up Your FCPA Compliance Now

Former Italian Prime Minister Silvio Berlusconi is no stranger to scandal and controversial statements, but lately his words and actions seem to be providing cause for concern outside of the European Union....more

Are Prosecutors Pushing the Envelope Too Far?

Federal prosecutors continue their aggressive enforcement of criminal laws against companies and individuals using aggressive investigative techniques, novel theories and new strategies which are testing the limits of due...more

Anti-Corruption Risks for Private Equity -- Portfolio Companies

The Justice Department and the SEC are targeting private equity companies for anti-corruption enforcement. Private equity companies are most at risk in their ownership of private equity companies....more

ANTI-CORRUPTION COMPLIANCE: DRILLING DOWN ON DOCUMENTATION

A key, but often overlooked, part of any anti-corruption compliance program is the need to document decisions made by the company. Documentation is critical to demonstrate the company's intent -- the absence of criminal...more

QUESTIONING CORPORATE CRIMINAL LIABILITY

The Obama Administration is aggressively prosecuting companies for criminal violations of anti-corruption, health care, labor and environmental laws. This article examines the aruments for and against imposing criminal...more

PERSON OF THE YEAR -- THE CHIEF COMPLIANCE OFFICER

The person of the year for 2011 -- The Chief Compliance Officer...more

MATERIALITY AND FCPA DISCLOSURES

This article examines the issue of materiality and FCPA disclosures...more

INTERNAL CONTROLS AND FOREIGN SUBSIDIARIES

This article examines how to design internals to protect against bribery by foreign subsidiaries...more

HEALTH CARE FRAUD AND COMPLIANCE

A look at health care fraud enforcement and compliance program elements...more

GLOBAL RETAILERS AND CORRUPTION RISKS

Global retailers ahve come udner scrutiny for FCPA violations -- this article examines the risks...more

FCPA VIOLATIONS AND COLLATERAL LITIGATION

An examination of collateral litigation risks from FCPA violations...more

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