This Week in FCPA-Episode 106 - the Back in the (FCPA) Saddle Again edition
In this weekly update, we summarise the most notable updates in the UK sanctions world. ...more
The Second Circuit Court of Appeals recently affirmed the confirmation of an arbitration award issued under a bilateral investment treaty between Libya and Cyprus. We previously described the underlying Southern District of...more
With energy markets already in tumult partly because of events in Ukraine and Iran, not to mention the OPEC production cut, another area of the world is now being convulsed by energy issues, with the prospect of natural gas...more
On 13 December 2021, the EU imposed sanctions against the Wagner Group, a private military entity based in Russia, as well as related entities and individuals, citing human rights abuses and destabilising activities in...more
Because of the world-wide disruptions caused by the COVID-19 virus, patent and trademark offices around the world have been reacting in a variety of ways such as extending deadlines, waiving fees or ceasing operations all...more
Sovereign States have, for a long time, enjoyed a degree of protection from the English courts under the State Immunity Act 1978. For example, absent a pre-agreed method of service such as on a service agent in England,...more
An arbitration award cannot be enforced in England against a foreign State without serving the proceedings on that State through the diplomatic channels. In General Dynamics UK Ltd v Libya [2019] EWHC 64 (Comm), Males LJ,...more
The U.S. Supreme Court Slows Children's Climate Lawsuit - For Now - "In the latest step of a fascinating bit of constitutional law called Atmospheric Trust Litigation, the Chief Justice halted the District Court trial...more
Legg Mason can finally close its books on the Gaddafi-era, Libyan bribery scandal. In June 2018, Legg Mason entered into a non-prosecution agreement with the Justice Department and agreed to pay $32 million for its role in...more
King’s back story of starting with the great psychedelic band Strawberry Alarm Clock and then moving to the Southern rockers Lynyrd Skynyrd, informs today’s blog post on the Legg Mason, Inc. (LM) Securities and Exchange...more
Sometimes it takes a large enforcement action to underscore basic and important anti-corruption compliance principles. The Société Générale enforcement action demonstrated two important principles – the dangers of a weak...more
Société Générale and Legg Mason carried out a massive bribery scheme to pay Gaddafi-era government officials in Libya in exchange for large investments by Libya government funds. In total, Société Générale and Legg Mason...more
In a one-two punch of FCPA enforcement actions, the Justice Department announced two related FCPA settlements involving Société Générale and Legg Mason for Gaddafi-era bribery payments to Libyan officials....more
With a wild ride of FCPA cases over the past week, Jay Rosen and I are back in the FCPA saddle again to take a look at some of the top compliance stories from the past week. 1. Société Générale S.A. becomes No. 5 in the...more
Legg Mason had engaged in a straight-forward bribery scheme and the perpetrators had actively engaged to hide it from the corporate headquarters. The bribery scheme involved Société Générale S.A. (SocGen) and the entity...more
The Department of Justice (DOJ) announced two Foreign Corrupt Practices Act (FCPA) enforcement actions earlier this week and the intertwined nature of these two enforcement actions informs today’s blog post....more
Now to be fair, Starbucks Executive Chair Howard Schultz has stepped away before. But this time feels more definitive, especially with the call of politics apparently swimming around in his post-Sbux plans....more
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) recently sanctioned six individuals, twenty-four entities, and seven vessels for their role in the exportation, refining, brokering, and sale of...more
In this hoganlovells.com interview, Hogan Lovells partner Laurent Gouiffès discusses oil and gas supply chain disruption and litigation trends in North Africa, including Algeria, Libya, Tunisia, Morocco, and Egypt....more
On Monday, June 5, 2017, Bahrain, Egypt, Libya's eastern region-based government, the Maldives, Saudi Arabia, United Arab Emirates ("UAE"), and the internationally recognized government of Yemen severed ties with Qatar,...more
Alien Tort Statute (ATS)/Political Question Doctrine/Foreign Sovereign Immunity Act (FSIA)/ Act of State Doctrine - District Court Dismisses ATS Claim Where Alleged Conduct in US was not Directly Linked to Injuries...more
After losing the emergency motion to stay the District Court’s Temporary Restraining Order (the “TRO”) halting the implementation of major portions of President Trump’s January 27th Executive Order, the administration has...more
Immigration has been in the forefront of the news since President Trump took office and will likely remain so in the near future. Here, we discuss three key business immigration issues that have seen significant developments...more
On February 9, 2017 the U.S. Court of Appeals for the Ninth Circuit issued a unanimous (per curiam) order denying the Federal Government's emergency motion for a stay of the district court order temporarily enjoining...more
On February 9, 2017, a three-judge panel of the U.S. 9th Circuit Court of Appeals ruled unanimously against the Government’s emergency motion to stay the District Court’s Temporary Restraining Order (the “TRO”) halting the...more