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Bribery Department of Justice (DOJ) Criminal Prosecution

Womble Bond Dickinson

Recent Anti-Corruption Updates

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Two recent court Foreign Corrupt Practices Act (FCPA) cases, a significant amendment to the Foreign Extortion Prevention Act (FEPA), and the new pilot whistleblower rewards program show that Anti-Corruption Enforcement...more

The Volkov Law Group

Lessons-Learned from the Trafigura FCPA Settlement (Part III of III)

The Volkov Law Group on

The Justice Department is rightly trumpeting its successful sweep of the commodities trading industry.  DOJ’s success is reflected in its six separate corporate resolutions and 20 individual convictions, resulting in over...more

The Volkov Law Group

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

The Volkov Law Group on

Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor.  At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more

The Volkov Law Group

Trafigura Joins the FCPA Enforcement Club: Pleads Guilty and Pays Over $126 Million for Bribery Violations in Brazil (Part I of...

The Volkov Law Group on

On the heels of the Gunvor FCPA settlement for $661 million, DOJ announced its settlement with Trafigura, the latest commodities trading company to fall under DOJ’s FCPA Sweep against the industry.  Trafigura joined the list...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 4 – Lessons Learned

We conclude our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action-Part 3-The Penalty

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary...more

Woodruff Sawyer

Dialing for Dollars: Taking Stock of The DOJ’s New Whistleblower Program

Woodruff Sawyer on

America has always loved stories about people who made it big. Abraham Lincoln grew up in a log cabin; 200 years later, he got his own biopic starring Daniel Day-Lewis. Oprah was born into poverty in rural Mississippi;...more

Benesch

White Collar Quarterly Report | Q1 2024

Benesch on

We are thrilled to introduce the inaugural issue of our quarterly White Collar newsletter, a dedicated resource from Benesch’s White Collar, Government Investigations & Regulatory Compliance Practice Group. Each issue...more

The Volkov Law Group

Gunvor’s Blockbuster FCPA Settlement: Lessons Learned and Trends (Part III of III)

The Volkov Law Group on

The Department of Justice’s blockbuster FCPA settlement with Gunvor restores the credibility of DOJ’s pronouncements of DOJ’s commitment to aggressive FCPA enforcement.  While I have questioned DOJ’s commitment to its...more

BakerHostetler

The Lines Are Open! DOJ Adds New Tool in Anticorruption Efforts With Whistleblower Pilot Program

BakerHostetler on

Building on the recent passage of the Foreign Extortion Prevention Act (FEPA), at the American Bar Association’s 2024 National Institute on White Collar Crime conference in San Francisco earlier this month (2024 ABA...more

The Volkov Law Group

Gunvor Falls Under FCPA Axe and Agrees to Pay Criminal Penalty of $661 Million (Part I of III)

The Volkov Law Group on

You have to give the Justice Department credit — after two slow enforcement years, DOJ is starting off 2024 with a relative “bang;” first, DOJ reached a large settlement with SAP in January, and now, DOJ has reached a...more

The Volkov Law Group

Former Stericyle Official Charged in Foreign Bribery Scheme

The Volkov Law Group on

According to the terms of a superseding information made public by the U.S. Attorney’s Office for the Southern District of New York on or about February 13, 2024, Mauricio Gomez Baez (“Baez”)—a former Stericycle executive for...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 1-Introduction

In March 2024, the Department of Justice (DOJ) announced the resolution of a FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action comes in with a $661 million penalty against the...more

WilmerHale

‘One eye across the Atlantic’ - The UK SFO Director’s Maiden Speech and Recent Visits to the United States Underscore the...

WilmerHale on

The Director of the UK Serious Fraud Office (SFO), Nick Ephgrave QPM, delivered his maiden public speech on February, 13, 2024, closely followed by visits to key financial centres in the United States to meet with...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 2: The Box Score of Corruption

We continue our exploration of the Foreign Corrupt Practices Act (FCPA) enforcement involving the German software company, SAP. The company agreed to pay the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

The SAP FCPA Enforcement Action-Part 1: Introduction

The year in Foreign Corrupt Practices Act (FCPA) enforcement started off with a bang on January 10 with the announcement of a resolution of the outstanding SAP enforcement action. The bribery schemes used by SAP were massive...more

Ballard Spahr LLP

DOJ Bolsters International Cooperation to Combat Corruption

Ballard Spahr LLP on

Summary - The Department of Justice (DOJ) has created the International Corporate Anti-Bribery initiative (ICAB), which aims to strengthen the United States’ global efforts in combating corruption through enhanced...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 4 – Internal Control Failures

Albemarle Corporation (Albemarle), recently agreed to pay more than $218 million to resolve investigations by the U.S. Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) into violations of the...more

A&O Shearman

Corficolombiana Pays $80M To Resolve Bribery Probes

A&O Shearman on

On August 10, 2023, the U.S. Securities Exchange Commission (“SEC”) and the Department of Justice (“DOJ”), in coordination with Columbian authorities, announced that Colombian conglomerate Grupo Aval Acciones y Valores S.A...more

Wilson Sonsini Goodrich & Rosati

What Companies Can Learn from the FirstEnergy/Ohio GOP “Dark Money” Scandal

In June, two prominent Ohioans were sentenced for their involvement in one of the largest political scandals in Ohio’s history. Former Speaker of the Ohio House of Representatives Larry Householder and former Chair of the...more

Wilson Sonsini Goodrich & Rosati

Charges Dropped Against Two “Varsity Blues” Parents After First Circuit Educates the DOJ on Proper Scope of Bribery, Fraud, and...

After 50-plus guilty pleas, dozens of prison sentences, and numerous courtroom victories, the U.S. Department of Justice (DOJ) is facing a major setback in its string of successful college admissions fraud cases. Weeks after...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for May 2023

Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more

Thomas Fox - Compliance Evangelist

2022-The Year in FCPA

2022 saw a relatively slow year in Foreign Corrupt Practices Act (FCPA) enforcement actions. Yet, as usual, the cases themselves were packed with much for the compliance professional to digest. Moreover, 2022 was a very...more

The Volkov Law Group

Corsa Coal Earns Declination and Agreed to Disgorge $1.2 Million

The Volkov Law Group on

The Justice Department has been pushing its voluntary self-disclosure program and changes to its Corporate Enforcement Policy, in an attempt to increase FCPA enforcement cooperation.  The Golden Ring for every company facing...more

The Volkov Law Group

Roger Ng, Former Goldman Sachs Banker, Sentenced to 10 Years’ Imprisonment For Role in 1MDB FCPA Scandal

The Volkov Law Group on

The end of the road for Roger Ng, the Goldman Sachs Investment Banker, who played a critical role in the Goldman Sachs 1 MDB Malaysia scandal, was not a pretty one.  District Judge Margo Brodie gave Ng a severe sentence of...more

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