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Brazil Oil & Gas Enforcement Actions

The Volkov Law Group

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

The Volkov Law Group on

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

The Volkov Law Group

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

The Volkov Law Group on

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

Foster Wheeler FCPA Action: Dancing with the Devil – Risky Third Parties (Part II of III)

The Volkov Law Group on

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

The Volkov Law Group

DOJ and SEC Announce First Corporate FCPA Settlement for 2021: Amec Foster Wheeler, a Wood Group Subsidiary, Agrees to Pay over...

The Volkov Law Group on

The Justice Department and the Securities Exchange Commission are back in business.  The first corporate FCPA enforcement action in 2021 came after a six-month hiatus in 2021.  While many commentators sought to read the...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

A&O Shearman

French Oil And Gas Company And U.S. Subsidiary Fined $296 Million Over Alleged Foreign Bribery Schemes Involving Brazil And Iraq

A&O Shearman on

On June 25, 2019, the Department of Justice (“DOJ”) announced that it had entered into a three-year deferred prosecution agreement (“DPA”) with TechnipFMC PLC to settle allegations of Foreign Corrupt Practices Act (“FCPA”)...more

Holland & Knight LLP

Petrobras Agrees to Pay More Than $1.8 Billion for Facilitating FCPA Violations

Holland & Knight LLP on

• Four years ago, Brazilian authorities began Operation Car Wash, a wide-ranging and still ongoing corruption and money laundering investigation that has spanned 11 countries. • The fallout continues with a recent U.S....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

The Volkov Law Group on

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

Bracewell LLP

Modern Enforcement: Rolls-Royce’s $800 Million Global Settlement

Bracewell LLP on

Rolls-Royce plc, a UK-based company that manufactures engines and generators for the aerospace, defense, marine, and energy sectors, has agreed to pay over $800 million to resolve parallel investigations by U.S., UK, and...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part IV – What Does it all Mean?

Today I conclude my series on the Rolls-Royce global anti-corruption enforcement action by taking a look what it all means going forward. The resolution is more than simply the stunning fines and penalties of £671 million...more

Cadwalader, Wickersham & Taft LLP

New Sheriff In Town As Rolls-Royce Pays Record Penalty For Foreign Bribery And Corruption

On 17 January 2017, the UK Serious Fraud Office (“SFO”),[1] the US Department of Justice (“DOJ”),[2] and the Brazilian Ministério Público Federal (“MPF”) announced an $800 million global settlement with Rolls-Royce plc and...more

Thomas Fox - Compliance Evangelist

Rolls Royce Global Enforcement Action-Part III, the US DPA

Today I continue my exploration of the Rolls-Royce global corruption enforcement action by considering the company’s resolution in the US under the Foreign Corrupt Practices Act (FCPA). Before we dive into that, I first...more

Thomas Fox - Compliance Evangelist

Rolls-Royce Global Enforcement Action: Part I

When most people across the globe think of Rolls-Royce, one word comes to mind – excellence. Yet that image largely relates to Rolls-Royce Limited, the automobile manufacturer, which was founded in 1909. Just a few years...more

Thomas Fox - Compliance Evangelist

George Carlin and Erga Omnes: the Petrobras Bribery Scandal Expands

On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more

Thomas Fox - Compliance Evangelist

The Petrobras Scandal and Corruption of Political Parties Under the FCPA

When does bribery and corruption move from a business issue to a political issue to a national issue? Why should US companies be held to the gold standard of anti-corruption laws? Should the US government even care if US...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

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