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Foreign Corrupt Practices Act (FCPA) Oil & Gas

Morgan Lewis

Energy Industry in the Government’s FCPA Crosshairs: Recent Enforcement and Policy Developments - Empowered

Morgan Lewis on

The energy industry in general and the oil and gas industry in particular has been the target of at least 50 Foreign Corrupt Practices Act (FCPA) prosecutions over the years—more than any other industry. Most of the cases...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

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

Thomas Fox - Compliance Evangelist

The Trafigura 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 G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more

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 3-the Discounted Fine

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

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

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

The Volkov Law Group

Ex-Vitol Oil & Gas Trader Convicted of Bribing Foreign Officials

The Volkov Law Group on

Following an 8 week trial, a federal jury in Brooklyn has convicted Javier Aguilar on charges relating to the former Vitol trader’s violations of the Foreign Corrupt Practices Act. He faces up to 30 years in prison. Aguilar...more

Bass, Berry & Sims PLC

International Trade Enforcement Roundup – November 2023 Update

Bass, Berry & Sims PLC on

You are reading the November 2023 Update of the Bass, Berry & Sims Enforcement Roundup, where we bring notable enforcement actions, policy changes, interesting news articles, and a bit of our insight to your inbox. ...more

Thomas Fox - Compliance Evangelist

Albemarle FCPA Enforcement Action: Part 2 – How to Hire Corrupt Agents

Last week, Albemarle Corporation (Albemarle), 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

The Volkov Law Group

Lessons Learned from the Albemarle FCPA Enforcement Action: Mind Your Third Parties (Part III of III)

The Volkov Law Group on

The Albemarle FCPA enforcement action was announced at a good time.  This year has been a slow year for DOJ’s FCPA enforcement program, although there are several months before the end of the year. The SEC, on the other hand,...more

The Volkov Law Group

Albemarle’s Reliance on Third-Parties to Execute Bribery Schemes (Part II of III)

The Volkov Law Group on

Albemarle’s bribery schemes look and sound like text-book examples of third-party agents being paid high commissions as a way to funnel bribery payments to foreign officials at state-owned oil refineries.  However, as usual,...more

The Volkov Law Group

Albemarle Settles DOJ and SEC FCPA Cases for $218 Million (Part I of III)

The Volkov Law Group on

Albemarle Corporation (Albemarle), a specialty chemicals manufacturing company located in Charlotte, North Carolina, agreed to pay more than $218 million to settle FCPA investigations with DOJ and the SEC stemming from...more

Morrison & Foerster LLP

Top 10 International Anti-Corruption Developments for August 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

The Volkov Law Group

Frank’s International Pays SEC $8 Million to Resolve FCPA Violations In Angola

The Volkov Law Group on

Franks International (“Frank’s”) settled FCPA charges with the SEC for $8 million stemming from operations in Angola during the period 2008 to 2014.  The Justice Department declined to prosecute Frank’s for the same events....more

The Volkov Law Group

DOJ Charges Two Oil and Gas Traders with FCPA Bribery Scheme Involving Petrobras

The Volkov Law Group on

In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras...more

Guidepost Solutions LLC

Mergers + Acquisitions: 5 Tips For Navigating FCPA Risks

Among the risks inherent in a merger or an acquisition, few bring the financial and reputational consequences of the U.S. Foreign Corrupt Practices Act (“FCPA”). Background - The FCPA prohibits the offer, promise,...more

Dechert LLP

Russia Sanctions: Where Are We Now and What Could Be Next?

Dechert LLP on

Since February 2022, the United States, United Kingdom, and European Union have imposed unprecedented economic sanctions on Russia and various Russian entities and individuals in response to the war in Ukraine. Actions have...more

Kohn, Kohn & Colapinto LLP

New Cop on a Bigger Block: The CFTC Steps into Enforcement of Anti-Corruption in Commodities Markets with Vitol Settlement.

The Commodity Exchange Act (CEA) tasks the Commodity Futures Trading Commission (CFTC) with regulating the U.S. derivatives markets. A December 3, 2020 , required it “to pay more than $95 million in civil monetary penalties...more

The Volkov Law Group

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

The Volkov Law Group on

We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues.  It does not take a rocket scientist to...more

The Volkov Law Group

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

The Volkov Law Group on

FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...more

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...more

The Volkov Law Group

Gunvor Group Employee Pleads Guilty to FCPA Scheme to Pay Bribes to Ecuadoran Government Officials

The Volkov Law Group on

Raymond Kohut, a 68-year old Canadian citizen, a former employee of Swiss commodities trader, Gunvor Group, Ltd., pleaded guilty to paying $22 million in bribes to Ecuadoran government officials at state-owned oil company,...more

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