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Oil & Gas Securities and Exchange Commission (SEC) Compliance

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)

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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)

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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)

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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

The Volkov Law Group

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

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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

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

Opportune LLP

What Does The Future Hold For ESG Reporting?

Opportune LLP on

As more ESG-linked funds flood the financial markets, increased scrutiny around ESG reporting will be necessary to enhance transparency....more

The Volkov Law Group

A Speak Up Culture Depends on Follow Through and Accountability

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Corporate leaders often talk to the talk when it comes to a Speak Up culture.  In theory, many business leaders can articulate their commitment to a Speak Up culture by emphasizing the importance of employees raising...more

Thomas Fox - Compliance Evangelist

The Panalpina Settlement Day Record May Finally Be Broken: The Unaoil Execs Guilty Pleas

Nine years ago today, on November 4, 2010, was Panalpina Settlement Day which made history for the single largest number of companies to simultaneously settle Foreign Corrupt Practices Act (FCPA)-related violations. It was...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - June 2019

ANTICORRUPTION DEVELOPMENTS - Deputy Assistant Attorney General Matt Miner Delivers Remarks at the American Bar Association, Criminal Justice Section Third Global White Collar Crime Institute Conference - On June 27,...more

The Volkov Law Group

Vantage Drilling Forks Over $5 Million for SEC FCPA Settlement

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The SEC announced last week a $5 million FCPA settlement with Vantage Drilling International (“Vantage”), a Texas-based offshore drilling company. ...more

Thomas Fox - Compliance Evangelist

The NPA; The Petrobras FCPA Enforcement Action: Part III

This blog post concludes my multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. Today we consider the stunning result achieved by Petrobras –...more

The Volkov Law Group

Petrobas Closes Out “Massive” Corruption Investigations and Litigation

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When it comes to a poster-child for corrupt organizations, there is very little competition that can eclipse Petrobas, the Brazilian state-owned oil and gas company. ...more

Thomas Fox - Compliance Evangelist

Farewell to Marty Balin; the Petrobras FCPA Enforcement Action: Part I

This blog post will begin a multi-part exploration of the Petróleo Brasileiro S.A. – Petrobras (Petrobras) Foreign Corrupt Practices Act (FCPA) enforcement action. The action was a stunning reminder of the costs of endemic...more

Thomas Fox - Compliance Evangelist

Rolls Royce in America – Four Guilty Pleas and an Indictment

For those who might have wondered if the Sessions Justice Department (DOJ) was going to enforce the Foreign Corrupt Practices Act (FCPA), that question seems to have been answered in the affirmative. In September, the DOJ and...more

Dorsey & Whitney LLP

Dorsey Anti-Corruption Digest - September 2017

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Keeping ahead of global anti-corruption trends is critical in today’s business markets. The Dorsey Anti-Corruption Digest, which puts global trends at your fingertips, puts you ahead. The deep experience of the Dorsey...more

Thomas Fox - Compliance Evangelist

ENI Receives ISO 37001 Certification and ENI CEO Charged with Corruption

Today’s headline is inspired by two recent notices; the first is from a January 25 ENI Press Release crowing that “Eni is the first Italian company to receive that certification”. The second came from an article in the...more

The Volkov Law Group

Five Key Takeaways from Key Energy’s SEC FCPA Settlement

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The SEC, last week, announced its $5 million settlement with Key Energy. As always, FCPA settlements contain important examples of enforcement priorities and policies. Key Energy’s recent settlement is an example of the...more

Thomas Fox - Compliance Evangelist

Key Energy FCPA Resolution – Part III

This week I have been exploring the Key Energy, Inc. (Key Energy) Foreign Corrupt Practices Act (FCPA) enforcement action. Today, I want to consider the actions taken by Key Energy to obtain the very good resolution the...more

Thomas Fox - Compliance Evangelist

Farewell to John Saunders and Welcome to Key Energy FCPA Resolution – Part I

John Saunders died last week. He was a reporter at ESPN and the host of the Sunday talking heads show, the Sports Reporters. The tributes for Saunders came from far and wide. By all accounts, he was one of the most beloved...more

Akin Gump Strauss Hauer & Feld LLP

SEC Adopts New Rules Requiring Disclosure of Resource Extraction Payments

On June 27, 2016, the Securities and Exchange Commission (SEC) adopted new rules requiring certain producers of oil, natural gas and minerals to publicly disclose information regarding payments to the U.S. federal government,...more

Thomas Fox - Compliance Evangelist

The Dalton Gang’s Last Stand and What is a Conflict of Interest?

On this day in 1982, the fabled Dalton Gang rode into Coffeyville, Kansas, supremely confident in its ability to simultaneously rob two banks in the town. When the dust settled, four of the five gang members lay dead. The...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

Thomas Fox - Compliance Evangelist

FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras

In this episode, Compliance Week Editor-in-Chief Matt Kelly and I discuss the Avon and Alstom FCPA enforcement actions and then take a look at the ongoing Petrobras corruption scandal and what it means for Brazil. ...more

Dorsey & Whitney LLP

Last Week In Securities Litigation (Week ending August 8, 2014)

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Last week the SEC brought an action this centered on hidden fees and a series of actions centered on microcap fraud and investment fund fraud. A pump and dump actions was filed centered on the manipulation of six different...more

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