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Foreign Corrupt Practices Act (FCPA) Criminal Conspiracy Compliance

The Volkov Law Group

BIT Mining Bribery Scheme — CEO Directed Payments and the Cover-Up (Part II of III)

The Volkov Law Group on

In reviewing FCPA bribery fact patterns, it is a rare occasion when a company’s CEO is at the epicenter of the criminal conspiracy. In the BIT Mining case, standing atop all of the actors is the CEO Zhengming Pan, Bit...more

The Volkov Law Group

U.S. Government Charges Parties with Violating U.S. Sanctions and Export Control Laws

The Volkov Law Group on

As we have repeatedly noted in the context of other blog posts and webinars in which various representatives of The Volkov Law Group have participated, the violation of existing U.S. sanctions and export control regulations...more

The Volkov Law Group

Gleaning the Inside of the Human Mind and Criminal “Intent”

The Volkov Law Group on

Prosecuting white collar crimes is a “mind game” in more ways than one.  This is another in my long series of profound grasps of the obvious. - As a former federal prosecutor, the difference between a crime and compliant...more

The Volkov Law Group

FCPA Potpourri: Catching Up with FCPA Enforcement

The Volkov Law Group on

While we wait for the coming FCPA enforcement storm, DOJ and the SEC have quietly continued to rack up and resolve several enforcement actions....more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The Individual Guilty Pleas

We rarely have seen a single Foreign Corrupt Practices Act (FCPA) enforcement action generate so many individual criminal pleas. The Sargeant Marine Inc. (Sargeant Marine) case is an exception. To date, there have been six...more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The Penalty

Recently we saw one of the most blatant cases of bribery and corruption brought by the Department of Justice (DOJ) in the form of a guilty plea by Sargeant Marine Inc. (Sargeant Marine), an asphalt company, related to...more

The Volkov Law Group

Sargeant Marine Pleads Guilty to FCPA Charges and Agrees to Pay $16.6 Million

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The Justice Department announced a guilty plea to FCPA charges by Sargeant Marine, Inc., a privately-owned company, based in Boca Raton, Florida.  Sargeant Marine, an asphalt company, plead guilty to one count of conspiracy...more

Thomas Fox - Compliance Evangelist

Sargeant Marine – The FCPA Enforcement Action

Recently we saw one of the most blatant cases of bribery and corruption brought by the Department of Justice (DOJ) in the form of a guilty plea by Sargeant Marine Inc. (Sargeant Marine), an asphalt company, related to...more

The Volkov Law Group

Justice Department Indicts Vitol Oil Trader in International Bribery and Money Laundering Conspiracy for Corrupt Payments to...

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A federal grand jury in the Eastern District of New York returned an indictment against Javier Aguilar, an oil trader at Vitol, an energy and commodity trading company, for his role in a five-year international bribery and...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 4 – Final Thoughts

We are the end of my multi-part exploration of the Herbalife Nutrition Ltd (Herbalife) Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 3 – Penalty Calculation and No Monitor

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Thomas Fox - Compliance Evangelist

The Herbalife FCPA Enforcement Action: Part 2 – Bribery Schemes and Numbers

Herbalife Nutrition Ltd (Herbalife) recently concluded a long running Foreign Corrupt Practices Act (FCPA) enforcement action with both the Department of Justice (DOJ) and Securities and Exchange Commission (SEC). Herbalife...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - December 2019

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

Society of Corporate Compliance and Ethics...

Ericsson agrees to pay more than $1 billion to settle FCPA case

CEP Magazine (February 2020)  - A subsidiary of Telefonaktiebolaget LM Ericsson, Ericsson Egypt Ltd., pleaded guilty on December 6 to a one-count criminal information charging it with conspiracy to violate the anti-bribery...more

WilmerHale

Foreign Corrupt Practices Act Alert - Global Anti-Bribery Year-in-Review: 2019 Developments and Predictions

WilmerHale on

Enforcement activity reached new heights in 2019. The year saw the two largest corporate resolutions in the history of the FCPA, corporate penalties paid to US enforcement agencies topped last year’s record levels, and...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

WilmerHale

$1 Billion Ericsson Resolution, Three Jury Verdicts Cap Off Busy Fourth Quarter for US FCPA Enforcement

WilmerHale on

On December 6, 2019, the Department of Justice (DOJ) and the Securities and Exchange Commission (SEC) agreed to resolve allegations that multinational telecommunications company Telefonaktiebolaget LM Ericsson (Ericsson or...more

A&O Shearman

Korean Engineering Company Fined $75 Million Over Alleged Foreign Bribery Scheme In Brazil

A&O Shearman on

On November 22, 2019, the U.S. Department of Justice (“DOJ”) announced that it had entered into a three-year deferred prosecution agreement (“DPA”) with a Korean engineering company (“SHI”) to settle allegations of Foreign...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Samsung FCPA Enforcement Action

Last week, another Foreign Corrupt Practices Act (FCPA) case was resolved. It involved Samsung Heavy Industries Company Limited (SHI), a South Korea-based engineering company that provides shipbuilding, offshore platform...more

The Volkov Law Group

Review of Samsung’s Bribery Scheme in Brazil (Part II of II)

The Volkov Law Group on

Samsung’s recent FCPA settlement with the Justice Department capped yet another example of a company involved in bribing Petrobas in Brazil for valuable contracts.  The scope of the bribery scheme was focused on a contingent...more

The Volkov Law Group

Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II)

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Samsung Heavy Industries agreed with the Justice Department to pay $75 million to settle FCPA charges. Under a three-year deferred prosecution agreement (DPA), Samsung agreed to filing of a criminal information in the Eastern...more

Thomas Fox - Compliance Evangelist

Another Guilty Verdict in a FCPA Trial – Mark Lambert

Last Friday, the Department of Justice (DOJ) secured another trial court conviction in a Foreign Corrupt Practices Act (FCPA) prosecution involving an individual. Following on the heels of the Hoskins guilty verdict, it...more

The Volkov Law Group

DOJ Charges Two Herbalife Executives with Criminal FCPA Violations

The Volkov Law Group on

Last week, DOJ announced the indictment of two former Herbalife executives in China for participating in a bribery scheme over a ten-year period.  Herbalife, a multi-level marketing company, was not charged and its...more

The Volkov Law Group

Alstom Executive Convicted on FCPA and Money Laundering Violations

The Volkov Law Group on

Lawrence Hoskins, a UK citizen and former Alstom executive, was convicted last Friday on 11 of 12 counts for his role in a bribery scheme involving Indonesian officials....more

The Volkov Law Group

Second Circuit Affirms FCPA Conviction of Ng Lap Seng and Rejects Application of Supreme Court’s McDonnell Decision to FCPA

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In an interesting decision, well worth a read, on August 9, 2019, the US Court of Appeals for the Second Circuit rejected Ng Lap Seng’s appeal of his 2017 conviction for bribery of united Nationals officials.  ...more

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