FCPA Compliance Report-Episode 302-Carlos Ayers on the Odebrecht Settlement from Brazil
You can always learn a lot from reviewing the underlying conduct to an FCPA enforcement action. Chief compliance officers can identify specific risk factors, mitigation steps and root causes for bribery schemes. ...more
Overview - A recent spate of cases on both sides of the Atlantic in 2023 show that criminal enforcement and asset recovery proceedings stemming from the iconic Brazilian anti-corruption investigation, Operation “Car Wash”...more
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
The Department of Justice is starting to launch its FCPA enforcement profile after a brief lull in DOJ’s transition to a new administration. This enforcement lull occurred in the transition to the prior administration in...more
DOJ announced the arrest of two individuals, Luis Martinelli Linares and Ricardo Martinelli Linares, who are the sons of the former President of Panama, Ricardo Martinelli) for their role in funneling $28 million in bribes to...more
ANTICORRUPTION DEVELOPMENTS – Canadian Mining Company Settles with SEC over FCPA Charges – On March 26, Kinross Gold Corporation settled with the Securities and Exchange Commission (SEC) over its alleged failure to...more
For over a year, Brazilian federal police could not access the files on Marcelo Odebrecht’s notebook computer. They tried using the password from Marcelo’s cell phones, with no luck. Originally published in The FCPA Blog -...more
In reaction to fallout from the recent Odebrecht scandal, and aided by shifting political winds, Peru and Argentina have enacted significant corporate anticorruption legislation. Both countries have implemented laws...more
ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards and...more
ANTICORRUPTION DEVELOPMENTS – Keppel Offshore Reaches Deal with DOJ and Guilty Plea by Counsel Unsealed – On December 22, 2017, Keppel Offshore & Marine Ltd. (KOM), a Singapore based company that operates shipyards...more
In recent years, U.S. and Western European military spending has decreased as military spending in other parts of the world has risen. As a result, aerospace, defense and government services (ADG) companies increasingly rely...more
As companies expand across borders and invest more heavily abroad, foreign enforcement authorities are following the example set by the U.S. Department of Justice and the U.S. Securities and Exchange Commission in directing...more
In this episode I visit with Carlos Ayers, a founding partner at the Sao Paulo law firm of Maeda, Ayres & Sarubbi about the state of anti bribery compliance in Brazil, how the Brazilian legal and compliance communities view...more
Within the SEC and DOJ’s blockbuster ending to 2016 was the Odebrecht settlement. The amount involved, a stunning $4.5 billion (pending a possible reduction for inability to pay), grabbed headlines around the world. But...more
Shearman & Sterling’s bi-annual Trends & Patterns in FCPA Enforcement report provides insightful analysis of recent enforcement trends and patterns in the US, the UK and elsewhere, as well as helpful guidance on emerging best...more