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
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
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
FCPA settlement actions often underscore specific compliance risks for legal and compliance professionals. If there ever was a case where third-party risks were bungled, and even intentionally embraced, the Foster Wheeler...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
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 from the past month, with links to primary...more
Annus horribilis. This is a moniker that oil and gas insiders might well apply to 2020 given the disastrous effects on the industry from Covid-19 pandemic (“Pandemic”) and its accompanying recession which brought a...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
The Justice Department continues to produce FCPA resolutions in a record year for enforcement. The latest, and perhaps the beginning of several end-of-year and end of the Trump Administration resolutions, is DOJ’s settlement...more
The UK Serious Fraud Office (the “SFO”) has reached a £1.2 million civil recovery settlement with Julio Faerman, a Brazilian national linked to the sprawling “Operation Car Wash” investigation involving the Brazilian...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
Enforcement authorities throughout the United States and Latin America are grappling with the impact of the COVID-19 pandemic, which is dramatically changing the economic landscape and is sure to change the enforcement...more