Salvador Dahan on the Journey of Petrobras
This Week in FCPA-Episode 122, the Kavanaugh, Rosenstein and 100+ Wins edition
D&O in Brazil and Latin America
FCPA Compliance and Ethics Report-Episode 122-with Matt Kelly on Alstom, Avon and Petrobras
Trafigura’s bribery scheme resembles the same schemes implemented by its significant competitors — Vitol, Glencore, Gunvor. At the core of the conduct, Petrobras and Brazilian government officials collected bribes in...more
We conclude our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary...more
We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international commodity trading company with its primary operations in...more
In March 2024, the Department of Justice (DOJ) announced the resolution of a Foreign Corrupt Practices Act (FCPA) enforcement action involving the Swiss trading firm G Trafigura Beheer B.V. (Trafigura), an international...more
The Justice Department’s FCPA enforcement record for 2024 was slow. This trend was unexpected, contrary to my own predictions and of various other prognosticators. It is hard to explain why this slowdown occurred....more
In its first enforcement action of 2023, the Justice Department charged a Connecticut man and a foreign national with FCPA bribery and money laundering charges stemming from a bribery scheme to secure contracts with Petrobras...more
The Honeywell FCPA settlement underscored a number of important issues – lessons learned for compliance professionals. Every FCPA case carries important lessons learned, but some more than others....more
The facts surrounding Honeywell’s bribery schemes in Brazil and Algeria are fairly straightforward. In Brazil, the facts underscore the significant risks of bribery when companies participate in large, valuable project...more
The Justice Department and the Securities and Exchange Commission had a strong FCPA enforcement year. However, there is certainly more to come and it is easy to predict that 2023 will be even a bigger year....more
The SEC announced another FCPA settlement in 2022. FCPA enforcement, in general, is picking up. Tenaris, a global supplier of steel pipes and related services for the energy industry, agreed to pay the SEC $78 million to...more
Operation Lava Jato (Carwash) had a profound effect on business in Brazil, with countless companies caught up in one way or another in the corruption scandal. State oil company Petrobras was no exception, but, as is the case...more
We all know and hear about third-party risks – over and over again. Despite this recurring theme, organizations continue to pay the price for failing to address third-party issues. It does not take a rocket scientist to...more
A pesar de los impactos de la pandemia del COVID-19, 2020 fue un año activo no solo para la aplicación de la Ley de Prácticas Corruptas Extranjeras (Foreign Corrupt Practices Act, FCPA), sino también para la lucha contra la...more
Despite the impacts of the COVID-19 pandemic, 2020 was an active year for Foreign Corrupt Practices Act (FCPA) enforcement - and anti-corruption enforcement more generally. Enforcement actions related to Latin America played...more
The Justice Department is coming to the close of a record FCPA enforcement year despite the disruptions caused by the pandemic. The Vitol case also represents the first parallel prosecution involving the Commodities Futures...more
Vitol’s bribery scheme stretched into three separate countries – Brazil, Ecuador and Mexico — and was carried out over a ten-year period. The Statement of Facts is instructive in describing the means by which Vitol used...more
J&F’s Investmentos bribery scheme was pervasive and was coordinated with a senior Brazilian Finance minister and orchestrated through the use of United States banking. The Brazilian official appears to be Guido Mantega, who...more
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
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
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
Last week there was the TechnipFMC plc (TechnipFMC) Foreign Corrupt Practices Act (FCPA) enforcement action, which was settled via a Deferred Prosecution Agreement (DPA)for TechnipFMC and a guilty pleafrom the company’s US...more
On March 5, 2019, King & Spalding hosted an Energy Forum, titled “Shifting Dynamics in Latin America”, to discuss the political and regulatory changes in Latin America and their impact on investments in energy. Latin...more
This is the sixth issue of WilmerHale’s 10-in-10 Hot Topics in Energy Series. Over the course of 10 weeks, our attorneys will share insights on current and emerging issues affecting the US energy sector....more
Despite predictions of a slow-down in enforcement under the Trump administration—and indications that enforcement in some areas has decreased in the past year1—2018 was yet again an active year for FCPA enforcement. The year...more