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White Collar Crimes Foreign Corrupt Practices Act (FCPA) Shell Corporations

The Volkov Law Group

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

The Volkov Law Group on

Gunvor’s bribery scheme is not very surprising nor ingenious.  After all, a number of energy trading companies have been prosecuted for bribery over the years, including Glencore, Vitol, Freepoint.  Numerous individuals have...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 2 – The Bribery Schemes

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

The Volkov Law Group

DOJ Charges Two Austrian Bankers with Money Laundering as Part of Massive Odebrecht Bribery Scheme

The Volkov Law Group on

The Department of Justice is starting to launch its FCPA enforcement profile after a brief lull in DOJ’s transition to a new administration.  This enforcement lull occurred in the transition to the prior administration in...more

The Volkov Law Group

J&F Investmentos FCPA Settlement: Lessons Learned (Part IV of V)

The Volkov Law Group on

J&F Investmentos (“J&F”) FCPA settlement presents a number of important lessons learned.  While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly...more

The Volkov Law Group

DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama

The Volkov Law Group on

DOJ announced the arrest of two individuals, Luis Martinelli Linares and Ricardo Martinelli Linares, who are the sons of the former President of Panama, Ricardo Martinelli) for their role in funneling $28 million in bribes to...more

The Volkov Law Group

DOJ Settles Follow-On FCPA Case: Transport Logistics Pays $2 Million Penalty

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Last week, the Justice Department announced its first FCPA enforcement action in 2018 – a follow-on settlement from prior FCPA enforcement actions centering on a bribery scheme involving a Russian government official from a...more

Robinson+Cole Manufacturing Law Blog

Settlement with Swedish Telecom Giant Falls Just Short of First $1 Billion FCPA Resolution

In September, the U.S. government announced a nearly $1 billion FCPA (Foreign Corrupt Practices Act) settlement with the Swedish telecommunications company Telia. The total monetary payment in this global resolution makes it...more

Thomas Fox - Compliance Evangelist

The Telia FCPA Resolution, Part I

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

The Volkov Law Group

Important Polling Results from BVD Webinar on Beneficial Ownership

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On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more

Thomas Fox - Compliance Evangelist

Red Flags Squelch Corrupt PDVSA Deal

As the Petrobras corruption scandal seems to be going strong, we turn our attention to what may be the most corrupt of all the national energy companies, the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA)....more

Thomas Fox - Compliance Evangelist

The Panama Papers and Shell Games, Part I

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

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