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Bribery Shell Corporations Foreign Corrupt Practices Act (FCPA)

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

DOJ Charges Two Austrian Bankers with Money Laundering as Part of Massive Odebrecht Bribery Scheme

The Volkov Law Group on

The Department of Justice is starting to launch its FCPA enforcement profile after a brief lull in DOJ’s transition to a new administration.  This enforcement lull occurred in the transition to the prior administration in...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

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

Robinson+Cole Manufacturing Law Blog

Settlement with Swedish Telecom Giant Falls Just Short of First $1 Billion FCPA Resolution

In September, the U.S. government announced a nearly $1 billion FCPA (Foreign Corrupt Practices Act) settlement with the Swedish telecommunications company Telia. The total monetary payment in this global resolution makes it...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

K&L Gates LLP

Are Your Company’s Legal, Due-Diligence, De-risking, or Compliance Obligations Impacted by the “Panama Papers”?

K&L Gates LLP on

In an unprecedented event earlier this week, 11.5 million files from the Panamanian law firm Mossack Fonseca were allegedly leaked. Assuming they are genuine, as appears to be the case, these “Panama Papers” offer a...more

The Volkov Law Group

IAP Worldwide FCPA Settlement: The Power of “Voluntary” Disclosure

The Volkov Law Group on

Okay, everyone take out their tea leaves and let’s get started on the IAP corruption case – DOJ announced a Non-Prosecution Agreement with IAP Worldwide Services and the criminal plea of a former executive who funneled bribes...more

Thomas Fox - Compliance Evangelist

British PM Leads The Fight Against Shell Corporations

One of the critical areas in due diligence for foreign business partners is determining who are the true owners of an entity....more

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