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Foreign Official Criminal Conspiracy

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

The Volkov Law Group

Three Individuals Charged with Fraud and FCPA Violations in International Adoption Scheme

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FCPA cases can arise in un usual situations.  DOJ has focused two separate prosecutions on bribery and fraud involving adoptions from Uganda and Poland.  At the heart, the defendants bribed Ugandan and Polish authorities to...more

Dorsey & Whitney LLP

UPDATE: Trial Court Overturns Former Alstom Executive’s Foreign Corrupt Practices Act Convictions

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Former Alstom SA executive Lawrence Hoskins’s jury convictions under the Foreign Corrupt Practices Act (“FCPA”) were set aside on February 26, 2020, by Judge Janet Bond Arterton of the United States District Court for the...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

WilmerHale

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

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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

Dorsey & Whitney LLP

Former Alstom Executive Convicted of Foreign Corrupt Practices Act Charges on Agency Theory

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Lawrence Hoskins, a British citizen and former employee of French conglomerate Alstom SA, has been found guilty by a federal jury in Connecticut of 11 of 12 criminal charges, including six counts of violating the United...more

Eversheds Sutherland (US) LLP

The Hoskins conviction and the implications of the DOJ’s success in using the money laundering statute to police bribery

The US Department of Justice (DOJ) is increasingly using the money laundering statute to prosecute individuals in corruption and bribery cases. The Foreign Corrupt Practices Act (FCPA) is the primary statute prohibiting...more

The Volkov Law Group

Episode 116 -- Alstom Executive Convicted of FCPA and Money Laundering Offenses

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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. Hoskins conviction took years to secure because of...more

Ballard Spahr LLP

Two Former Venezuelan Officials and Energy Executives Indicted as DOJ Continues to Use Money Laundering Charges to Combat Foreign...

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Last week, a grand jury in the Southern District of Florida indicted two former Venezuelan officials, charging them with seven counts of money laundering and one count of money-laundering conspiracy. The charges relate to...more

Orrick, Herrington & Sutcliffe LLP

Foreign Corrupt Practices Act (FCPA) - The World in U.S. Courts: Summer - Fall 2018

Conspiracy and Aiding-and-Abetting Charges Cannot Expand Territorial Reach of the FCPA to a Non-US Defendant Who Otherwise Would Not Be Liable for His Ex-US Conduct - United States v. Hoskins, US Court of Appeals for the...more

Dorsey & Whitney LLP

The FCPA and Foreign Nationals

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Despite the fact that the Foreign Corrupt Practices Act has been in force for decades there is relatively little case law interpreting its provisions. A great deal of the existing interpretation of the Act stems from...more

Ballard Spahr LLP

8 Charged With Highly Sophisticated $1.2 Billion International Money Laundering Conspiracy

Ballard Spahr LLP on

On July 24, 2018, the United States Attorney’s Office for the Southern District of Florida unsealed a criminal complaint (the “Complaint”) charging eight individuals with conspiracy to commit money laundering under 18 U.S.C....more

Thomas Fox - Compliance Evangelist

Transparency, FCPA Enforcement and the Rule of Law

In a win for transparency, the rule of law and the international fight against bribery and corruption, the Department of Justice (DOJ) secured a victory in all three categories with the sentencing of Egbert Yvan Ferdinand...more

The Volkov Law Group

Justice Department Closes Out 2017 with 2 FCPA Actions: Keppel Offshore and Marine and Embraer Individual

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The Department of Justice finished 2017 with two significant FCPA enforcement actions, and fittingly, one was a corporate settlement and another was an individual criminal guilty plea. The Justice Department’s final FCPA...more

The Volkov Law Group

The FCPA Week That Was — Seven Individuals Charged for FCPA Violations

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To all the “nattering nabobs of negativity” concerning FCPA enforcement, the US Justice Department responded with a resounding message – not only is FCPA enforcement here to stay, but individual violators are on DOJ’s radar...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

Fenwick & West LLP

You’re the Man—Government Targets Individuals in FCPA Cases

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The government has increasingly focused its FCPA enforcement firepower on individuals. On August 31, a Russian official living in Maryland pled guilty to conspiracy to commit money laundering in connection with arranging $2...more

Fenwick & West LLP

Securities Litigation and Enforcement Newsletter

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A CD or not a CD, That is the Question… That the Auditors Should Have Answered - A headline-grabbing SEC enforcement action last week against BDO USA and several of its national partners may lead audit firms to insist on...more

Morrison & Foerster LLP

Top Ten International Anti-Corruption Developments for August 2015

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments in the past month, with links to primary...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations & White Collar Defense - September 2015

No Dog Days of August for the SEC—A Recap of a Busy Month - Why it matters: Who says there is a government slowdown in August? Not for the SEC. August 2015 turned out to be very busy indeed for the agency, which...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - August 2015

Welcome to the August 2015 edition of Red Notice, a publication of Akin Gump Strauss Hauer & Feld LLP. This month on the anticorruption front, the U.S. Department of Justice (DOJ) and the U.S. Securities and Exchange...more

Dorsey & Whitney LLP

Foreign Official Pleads Guilty In Connection with FCPA Conspiracy

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The Foreign Corrupt Practices Act was aimed at halting corrupt payments made to improperly influence foreign officials. In drafting the Act Congress chose not to impose liability on the foreign official involved in corrupt...more

WilmerHale

Federal Judge Rejects DOJ’s Theory of FCPA Accomplice Liability

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On August 13, 2015, a US district judge dismissed a charge seeking to hold a defendant criminally liable for conspiracy to violate the Foreign Corrupt Practices Act (FCPA) if he is not a principal or agent of a US domestic...more

Dorsey & Whitney LLP

DOJ–Louis Berger, Two Executives Resolve FCPA Charges

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The DOJ resolved another FCPA action with the company entering into a deferred prosecution agreement, paying a criminal fine and agreeing to the imposition of a monitor after self reporting and cooperating. Two of the firm’s...more

Morrison & Foerster LLP

Conviction of First Foreign Official at Trial for Money Laundering Based on Underlying FCPA Bribery Scheme Upheld

Following on the heels of its landmark 2014 ruling in United States v. Esquenazi, the Eleventh Circuit has issued another important decision addressing the Foreign Corrupt Practices Act (FCPA) in a related case, United States...more

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