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Brazil Compliance Corruption

The Volkov Law Group

Trafigura’s Bribery Scheme: Clandestine Meetings, 3rd Parties and Shell Companies (Part II of III)

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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

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action – Part 4 – Lessons Learned

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

Thomas Fox - Compliance Evangelist

The Trafigura FCPA Enforcement Action-Part 3-The Penalty

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

American Conference Institute (ACI)

[Webinar] Anti-Corruption Brazil – FCPA Compliance and Enforcement in Brazil: DOJ and SEC Alumni Provide Critical Updates and the...

American Conference Institute’s expert faculty of DOJ and SEC alumni will update you with the most recent developments and risk factors confronting industry in Brazil and will lay out practical takeaways for satisfying the...more

World Law Group

2022 Anti-corruption Guide - Brazil

World Law Group on

1. Is your country a member of the OECD Anti-Bribery Convention? Yes. 2. Is your country a member of any other bilateral or multilateral conventions on anti-corruption? Yes. Brazil is also a member of the Inter-American...more

The Volkov Law Group

A Deep Dive into WPP’s Bribery Schemes in India, China, Brazil and Peru (Part II of III)

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The SEC’s FCPA settlement with WPP for over $19.2 million provides a variety of bribery schemes in several high-risk venues. The schemes are instructive because they remind anti-corruption compliance professionals of the...more

The Volkov Law Group

Lessons Learned: Foster Wheeler FCPA Settlement Underscores Danger of Third-Party Risks (Part III of III)

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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

The Volkov Law Group

Vitol’s Bribery Schemes in Brazil, Ecuador and Mexico (Part II of III)

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

J&F – The SEC Order

Today, I continue a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

The Volkov Law Group

DOJ FCPA Settlement: J&F Investmentos’ Bribery Schemes (Part II of V)

The Volkov Law Group on

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

Thomas Fox - Compliance Evangelist

J&F – The Bribery Schemes

Last week, I began a multi-part exploration of one world’s largest anti-corruption enforcement actions, the J&F Investimentos SA (J&F) matter. It involved huge fines and penalties in both Brazil and the United States. Of...more

Thomas Fox - Compliance Evangelist

HorrorFest 2020 Celebration: The Revenge of Frankenstein and the J&F FCPA Resolution

In this third edition of October HorrorFest 2020 celebration we consider the first Hammer film sequel (and second in the series) – The Revenge of Frankenstein which was released in 1958. It begins as the Curse of Frankenstein...more

Thomas Fox - Compliance Evangelist

The Miller & Chevalier 2020 Latin American Corruption Survey

This week on the FCPA Compliance Report, I will have a special five-part podcast series taking a deep dive into the Miller & Chevalier Chartered 2020 Latin American Corruption Survey. I will visit with firm lawyers James...more

The Volkov Law Group

FCPA Predictions for 2020 (Part III of III)

The Volkov Law Group on

It is time to break out the crystal ball for FCPA 2020 Predictions.  In preparing for this, I always rely on my past admiration of Carnac the Magnificent....more

A&O Shearman

Korean Engineering Company Fined $75 Million Over Alleged Foreign Bribery Scheme In Brazil

A&O Shearman on

On November 22, 2019, the U.S. Department of Justice (“DOJ”) announced that it had entered into a three-year deferred prosecution agreement (“DPA”) with a Korean engineering company (“SHI”) to settle allegations of Foreign...more

Thomas Fox - Compliance Evangelist

Lessons Learned from the Samsung FCPA Enforcement Action

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

The Volkov Law Group

Samsung Agrees to Pay $75 Million to Resolve FCPA Violations (Part I of II)

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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

King & Spalding

Q3 2019: Latin America Enforcement Review

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Enforcement authorities throughout the United States and the Americas continue to aggressively investigate fraud and corruption across the region in the third quarter of 2019. Below, we highlight some recent developments and...more

King & Spalding

H1 2019: Latin America Enforcement Observations

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The U.S. Justice Department, the U.S. Securities and Exchange Commission, and their enforcement partners throughout Latin America remain focused on actively investigating corruption activities and bringing enforcement actions...more

Burr & Forman

Walmart FCPA Settlement Shines Light On Corporate Compliance Programs

Burr & Forman on

June 20, 2019 – Walmart (NYSE: WMT) and its subsidiary, WMT Brasilia, agreed to a combined criminal penalty and disgorgement of $282M, together with WMT’s criminal guilty plea and undertakings in an NPA, to reach a global...more

Thomas Fox - Compliance Evangelist

Walmart FCPA Enforcement Action: Part 1 – Introduction

The big one finally is resolved. The long-awaited Walmart Inc. (Walmart) Foreign Corrupt Practices Act (FCPA) enforcement action was announced yesterday. This massive case came in with multiple documents, a long list of...more

Thomas Fox - Compliance Evangelist

Major Sporting Event Hospitality: Part I – Telefônica Brasil

Asking a Brazilian-based company not to use the World Cup as a business development opportunity, most particularly when Brazil is hosting the World Cup, seems to be highly unlikely....more

WilmerHale

Foreign Corrupt Practices Act Enforcement in the Energy Sector

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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

Thomas Fox - Compliance Evangelist

Rumble, Regime Change and Compliance

This one is for all you rock and roll mavens out there. Can you name the only instrumental song which was banned from radio play? That is correct, a song with no lyrics was banned as being “too subversive”. It is of course,...more

WilmerHale

Foreign Corrupt Practices Act Alert: Global Anti-Bribery Year-in-Review: 2018 Developments and Predictions for 2019

WilmerHale on

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

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