News & Analysis as of

Enforcement Actions Foreign Corrupt Practices Act (FCPA) Fines

The Volkov Law Group

DOJ Awards Declination to Proterial Cable America for Fraud — Proterial Pays $15.1 Million in Disgorgement

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DOJ is pushing hard for voluntary disclosures and urging companies to take advantage  of its Voluntary Disclosure Program.  The carrot is significant — a declination in exchange for cooperation, remediation and disgorgement....more

The Volkov Law Group

DOJ Issues New FCPA Declination: Boston Consulting Group Pays $14.4 Million

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The Justice Department is encouraging companies to voluntarily disclose criminal violations — “Come in and confess” and DOJ offers promises of a declination.  But even a declination comes with a requirement — the company has...more

The Volkov Law Group

CFTC Fines Trafigura $55MM for Market Abuses, Interfering with Whistleblower Communications

The Volkov Law Group on

On June 17, 2024, the U.S. Commodity Futures Trading Commission (CFTC) announced that trading giant Trafigura had agreed to pay a $55 million fine to settle charges of fraud and manipulation. The conduct at issue allegedly...more

Fisher Phillips

Deal of a Lifetime – or Jailtime and Fines? 5 Best Practices to Avoid Foreign Corrupt Practices Act Violations

Fisher Phillips on

One of your employees working overseas emails you with great news – they’re about to close a $50 million sale with a new customer. They tell you everything looks great, but there’s just one thing. The local political party...more

Orrick, Herrington & Sutcliffe LLP

SEC fines gaming company $4 million as successor to a company charged with FCPA violations

On March 6, the SEC announced that an Ireland-based global gaming and sports betting company, as successor-in-interest to a company it acquired in 2020 (the “acquired company”), agreed to pay a $4 million civil money penalty...more

McGuireWoods LLP

Brazilian Airline to Pay Millions in Coordinated Foreign Bribery Resolution

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On September 15, 2022, GOL Linhas Aéreas Inteligentes S.A. (GOL), Brazil’s second largest domestic airline, resolved long-running parallel investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange...more

The Volkov Law Group

DOJ and SEC Secure $41 Million Settlement from Brazilian Airline for FCPA Violations (Part I of II)

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The Department of Justice and the Securities and Exchange Commission reached a $41 million settlement with GOL Linhas Aéreas Inteligentes S.A. (“GOL”) to resolve criminal and civil foreign bribery charges....more

Thomas Fox - Compliance Evangelist

HorrorFest 2020 Celebration: The Revenge of Frankenstein and the J&F FCPA Resolution

In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more

Health Care Compliance Association (HCCA)

Sculptor Capital Management Inc. agrees to pay fine to resolve a Foreign Corrupt Practices Act case

Compliance Today (October 2020) - In a case that has remained unresolved for almost a decade, Sculptor Capital Management Inc., formerly Och-Ziff Capital Management, agreed to pay investors in a Congolese mine, who were...more

The Volkov Law Group

Three Former Executives from Alstom and Marubeni Charged with Criminal FCPA Violations in Indonesia

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In its continuing aggressive FCPA criminal enforcement program, DOJ announced the indictment of two former Alstom executives and a former Marubeni executive with FCPA violations arising from a bribery scheme in Indonesia....more

Skadden, Arps, Slate, Meagher & Flom LLP

Ericsson Agrees To Pay Over USD $1 Billion To Settle FCPA Charges

On December 6, 2019, Telefonaktiebolaget LM Ericsson (Ericsson or the Company), resolved long-running investigations by the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange Commission (SEC) into the...more

Thomas Fox - Compliance Evangelist

Top Five Department of Justice FCPA Enforcement Actions in 2019

Welcome to the 2020’s. The past decade helped shape both Foreign Corrupt Practices Act (FCPA) enforcement and corporate compliance programs. 2019 FCPA enforcements bore out many of the developments from the preceding years of...more

Thomas Fox - Compliance Evangelist

The Panalpina Settlement Day Record May Finally Be Broken: The Unaoil Execs Guilty Pleas

Nine years ago today, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. It was...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2019

ANTICORRUPTION DEVELOPMENTS - Telecommunications Company Fined $12 Million for FCPA Violations - On August 29, 2019, The Securities and Exchange Commission (SEC) instituted ceaseand-desist proceedings against...more

Hanzo

Hanzo's 2018 FINRA AND SEC Regulatory Compliance Year in Review

Hanzo on

From Elon Musk’s tweets to Floyd Mayweather and DJ Khaled’s promotion of cryptocurrencies, 2018 was, to say the least, an interesting year in regulatory enforcement news. Even if all you do is win, win, win, no matter what,...more

Thomas Fox - Compliance Evangelist

Farewell to Marty Balin; the Petrobras FCPA Enforcement Action: Part I

This blog post will begin a multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. The action was a stunning reminder of the costs of endemic...more

Moore & Van Allen PLLC

Is the Trump Administration Charting a New Course Away from the Duplicative Fines of the Financial Crisis?

Moore & Van Allen PLLC on

Double jeopardy prevents criminal defendants from being convicted of the same crime twice. Res judicata prevents civil litigants from facing repeated claims by an overly aggressive plaintiff. Unfortunately, in the years after...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - June 2017

ANTICORRUPTION DEVELOPMENTS - Linde Group Receives DOJ Declination Pursuant to FCPA Pilot Program - On June 16, 2017, German based chemical and gas company Linde Group’s American affiliates, Linde North America Inc....more

Thomas Fox - Compliance Evangelist

A ‘Most Daring Act’ and the SQM FCPA Enforcement Action – Part I

A most “daring act” seems to be a good way to introduce a multi-part look at the recent Foreign Corrupt Practices Act (FCPA) enforcement action involving the Chilean chemicals and mining company Sociedad Química y Minera de...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part I

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more

Thomas Fox - Compliance Evangelist

General Cable FCPA Enforcement Action – Part II: The Comeback

Yesterday I began an exploration of the General Cable Corporation (General Cable) Foreign Corrupt Practices Act (FCPA) enforcement action. It was settled with the DOJ via a Non-Prosecution Agreement (NPA) and the SEC via a...more

Thomas Fox - Compliance Evangelist

General Cable FCPA Enforcement Action – Part I: The Bribery Schemes

The Department of Justice (DOJ) and Securities and Exchange Commission (SEC) continued their stunning run of 2016 Foreign Corrupt Practices Act (FCPA) enforcement actions right up to the end of the year with the announcement...more

Thomas Fox - Compliance Evangelist

Teva FCPA Enforcement Action-Part I

Just when you were thinking things could not get any bigger after the Odebrecht/Braskem Foreign Corrupt Practices Act (FCPA) enforcement action, the Department of Justice (DOJ) and Securities and Exchange Commission (SEC)...more

Thomas Fox - Compliance Evangelist

Embraer FCPA Enforcement Action – Part III

Today I continue my exploration of the recently announced Department of Justice (DOJ) and Securities and Exchange Commission (SEC) Foreign Corrupt Practices Act (FCPA) enforcement action with the announcement of the...more

King & Spalding

SEC Cracks Down on Charitable Contributions under the FCPA - Best Practices In Light of Recent SEC Enforcement

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For the first time, the Securities and Exchange Commission has brought an FCPA enforcement action premised entirely on a one-time charitable contribution. On September 20, 2016, the SEC announced a settled FCPA...more

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