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Bribery Shell Corporations Compliance

The Volkov Law Group

Gunvor’s Bribery Schemes — Third-Parties, Shell Companies and Evasion of Controls (Part II of III)

The Volkov Law Group on

Gunvor’s bribery scheme is not very surprising nor ingenious.  After all, a number of energy trading companies have been prosecuted for bribery over the years, including Glencore, Vitol, Freepoint.  Numerous individuals have...more

Thomas Fox - Compliance Evangelist

The Gunvor FCPA Enforcement Action: Part 2 – The Bribery Schemes

We continue our exploration of the resolution of the FCPA enforcement action involving the Swiss trading firm Gunvor S.A. The enforcement action came in with a $661 million penalty against the company, which has pleaded...more

The Volkov Law Group

J&F Investmentos FCPA Settlement: Lessons Learned (Part IV of V)

The Volkov Law Group on

J&F Investmentos (“J&F”) FCPA settlement presents a number of important lessons learned.  While the bribery scheme was brazen and involved a large amount of money, the techniques and warning signs must have been fairly...more

The Volkov Law Group

DOJ Charges Two Sons of Former Panama President Martinelli with Participation in Odebrecht Bribery Scheme in Panama

The Volkov Law Group on

DOJ announced the arrest of two individuals, Luis Martinelli Linares and Ricardo Martinelli Linares, who are the sons of the former President of Panama, Ricardo Martinelli) for their role in funneling $28 million in bribes to...more

Thomas Fox - Compliance Evangelist

Farewell to the Emperor, Another Guilty Plea in Petroecuador and (Of Course) Carlos Correa

It seems somehow fitting this week in the midst of the Astros inexorable march back to the World Series that we honor the only baseball player across the globe simply known as “The Emperor”. He was, of course, Masaichi Kaneda...more

Thomas Fox - Compliance Evangelist

Farewell to Volkoff and to Shell Companies

Weirdly, Volkoff informs today’s post and not simply because of President Trump’s fawning over all things Russian. We wrap-up the blog series about the continuing dangers of shell companies, as articulated by Ryan C. Hubbs,...more

Thomas Fox - Compliance Evangelist

Chaucer, the Canterbury Tales and Shell Companies

According to Samuel Rubenfeld, reporting in the Wall Street Journal (WSJ) Risk & Compliance Journal, “Treasury Secretary Steven Mnuchin told lawmakers that he wants to make corporate ownership information available to law...more

The Volkov Law Group

DOJ Settles Follow-On FCPA Case: Transport Logistics Pays $2 Million Penalty

The Volkov Law Group on

Last week, the Justice Department announced its first FCPA enforcement action in 2018 – a follow-on settlement from prior FCPA enforcement actions centering on a bribery scheme involving a Russian government official from a...more

Thomas Fox - Compliance Evangelist

The Telia FCPA Resolution, Part I

While the resolution of the Telia Company (Telia) Foreign Corrupt Practices Act (FCPA) matter has long been awaited, the results announced yesterday by the Department of Justice (DOJ) and Securities and Exchange Commission...more

The Volkov Law Group

Important Polling Results from BVD Webinar on Beneficial Ownership

The Volkov Law Group on

On July 5, 2017, Bureau Van Dijk, a sponsor of my blog, conducted a webinar on the importance of beneficial ownership information to corporate compliance functions....more

Thomas Fox - Compliance Evangelist

Red Flags Squelch Corrupt PDVSA Deal

As the Petrobras corruption scandal seems to be going strong, we turn our attention to what may be the most corrupt of all the national energy companies, the Venezuelan state oil company Petroleos de Venezuela SA (PDVSA)....more

The Volkov Law Group

Mitigating Bribery Risks With Financial Controls

The Volkov Law Group on

Anti-corruption compliance is not as hard as it looks. In fact, by taking a step back, compliance professionals can gain insights. At the direction of compliance professionals, companies like to develop and adopt...more

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